Tax Executives Institute, Inc.
TEI
Tax Executives Institute is the preeminent association of in-house business tax executives worldwide.
ID: 52413445902-12
Lobbying Activity
Response to Evaluation of the Anti-Avoidance Tax Directive (ATAD)
10 Sept 2024
Dear Sir or Madam: Please find attached comments of Tax Executives Institute, Inc., regarding the Anti-tax Avoidance Directive evaluation. Sincerely, Benjamin R. Shreck Tax Counsel Tax Executives Institute, Inc.
Read full responseResponse to Public country-by-country on corporate - template and electronic format
28 Aug 2024
Dear Sir or Madam - please find in the attached file comments of Tax Executives Institute, Inc. on this consultation. Sincerely, Benjamin R. Shreck Tax Counsel Tax Executives Institute, Inc.
Read full responseResponse to Business in Europe: Framework for Income Taxation (BEFIT)
22 Jan 2024
Please find attached comments of Tax Executives Institute, Inc. ("TEI"). Should you have any questions regarding TEI's comments, please reach out to Benjamin R. Shreck of TEI's legal staff at bshreck@tei.org.
Read full responseResponse to Business in Europe: Framework for Income Taxation (BEFIT)
3 Jan 2024
Please find attached comments of Tax Executives Institute, Inc. ("TEI") regarding the proposal for a council directive on transfer pricing. Should you have any questions regarding our comments please reach out to Benjamin Shreck of TEI's legal staff at bshreck@tei.org.
Read full responseResponse to VAT in the Digital Age
3 Apr 2023
Tax Executives Institute commends the Commission's extensive work on this initiative. We particularly agree with and welcome efforts to standardize VAT reporting obligations and prevent introduction of uncoordinated variances by Member States. We also welcome extension of deemed supplier rules for supplies of goods within the EU, which not only simplifies business processes, but also better respects the horizontal neutrality of both EU and non-EU established businesses. The proposed measure whereby platforms would have to account for VAT when they move goods owned by the underlying sellers across EU-borders, instead of the underlying seller, is also appreciated, as it will prevent sellers (albeit largely smaller sellers) from having to register in multiple EU Member States. With respect to the platform economy, we commend the Commissions efforts to harmonize the VAT treatment of short-term rentals across the EU. In view of minimizing administration and compliance costs, we support the Commission in further streamlining reporting and recordkeeping obligations for electronic interfaces and platforms, ideally by only requesting the same data once. While TEI members enthusiastically support the above aspects of the Proposal, we do believe additional work is necessary. As with any undertaking of this magnitude, the devil is in the details, and there remain significant opportunities to further harmonize the European VAT system, increase horizontal neutrality, and eliminate unnecessary administrative burden. To this end, we have identified a number of concerns in portions of the Proposal pertaining to VAT reporting obligations, the Platform Economy, and the single VAT registration. These concerns are listed below and discussed more broadly in the attachment. Concerning VAT reporting obligations, we urge the Commission to: integrate Intrastat reporting obligations; expand the implementation period for new e-invoicing requirements to a minimum of 18 months beginning on the date that final rules are published; add status of registrations to VIES; adopt a unified method of data transmission; broaden the two-working-day requirement to a minimum period of two weeks; proscribe Member States from requiring additional invoice requirements; allow use of summary invoices in limited circumstances when it is impracticable to match buyer and seller data on a transactional basis; allow flexibility in issuing and reporting credit invoices; consider eliminating the proposed addition of IBAN numbers on invoices; consider adding optional, simplification measures, such as the use of paper invoices, for businesses with gross revenues below a designated threshold; and clarify various terms and concepts noted in the attachment. Concerning the Platform Economy, we urge the Commission to: conduct further study on the tourism sector before proposing changes; adopt a council regulation to support proposed expansion of the deeming provision to electronic interfaces; align the proposed place-of-supply rules with principles in the OECD VAT/GST Guidelines; expand the OSS to avoid unnecessary administrative burden; resolve unequal VAT treatment for platforms providing the same travel agent services; streamline reporting obligations to avoid creating a barrier for start-ups and innovative companies; and clarify various terms and concepts noted in the attachment. Concerning the single VAT Registration, we urge the Commission to: reconsider the proposed treatment of supply of second-hand goods, works of art, etc. as Intra-Community sales of goods; reevaluate the benefits of the proposed unique consignment number against the costs and administrative burdens of implementing it; extend the IOSS, OSS, and Single VAT Return to allow for recovery of input-VAT; integrate Intrastat reporting obligations with the special scheme for a businesss transfer of its own goods, and clarify various terms and concepts noted in the attachment.
Read full responseResponse to Debt equity bias reduction allowance (DEBRA)
29 Jul 2022
Please find attached comments of Tax Executives Institute, Inc. ("TEI") regarding the proposed debt-equity bias reduction allowance directive.
Read full responseResponse to Fighting the use of shell entities and arrangements for tax purposes
5 Apr 2022
On behalf of Tax Executives Institute, Inc. ("TEI"), please find attached a letter to the European Commission providing TEI's feedback on the proposed directive regarding the misuse of shell entities for tax purposes.
Read full responseResponse to VAT in the Digital Age
17 Mar 2022
Technology is a great enabler, but to improve the EU VAT system, technology must be built and used on a modern foundation that reflects current business practices. When designing a digital reporting solution, the following design criteria should be applied:
(a) Efficient enabling of automation for both tax administrators and companies, while respecting proportionality between administrative burden and safeguarding VAT revenues
(b) Respect of existing business processes and generally used IT system designs to the greatest extent possible
(c) Achieving efficiency through stakeholder (i.e., business) collaboration from the technology design all the way towards implementation
(d) Standardisation across the EU, creating one system/process that can be used in every country and for all transactions
(e) Closed list of data-points across the EU, ensuring availability of the required information and allowing for more flexibility while limiting administrative costs
(f) Allowing for corrections based on the universal acknowledgment that reporting solutions are dependent on master-data where errors can inadvertently be made but, upon detection, should allow for an easy and efficient correction process
(g) Preserving flexibility with companies deciding on the type of solution (e.g., e-invoicing, real time reporting, or SAF-T) to be applied
(h) Guaranteeing data-security when requiring the transfer of personal and business confidential information outside a company-controlled IT environment
(i) Respecting implementation time required when translating reporting obligations into IT requirements and implementation
Any approach should accept the non-renewal of existing Implementing Decisions or other measures that prevent a harmonized approach and also respect technological investments already made by businesses to continue or interoperate at least in the short to mid-term.
The platform economy has magnified pre-existing EU VAT system challenges, and it is critical to consider such challenges before deciding upon any new measures. In addition to the above, the following elements should be considered in the proposed measures:
(a) Accepting diversity and striking a balance whereby diversity in the types of platforms and their evolution (which is ongoing) is accepted and collection obligations are not generically applied to all, but rather the right balance is struck considering factors, such as the size and type of the platform, its ability to comply, and administrative burdens of compliance
(b) Considering all actors involved in the platform economy and ensuring a balanced approach
(c) Clarification and community-wide delimitation of specific concepts, such as “electronic service” and “intermediary service” thereby ensuring a consistent application across the EU
(d) Preserving horizontal neutrality so the supply of similar goods and services are treated equally in all Member States, irrespective of the supply channel involved or the country of establishment
(e) Proportionality and alignment in compliance obligations for platforms. Today, largely irrespective of their size, platforms are subject to the DAC7 provisions and VAT provisions. However, another set of customs reporting obligations are being proposed. We encourage alignment of administrative obligations with the size of the platform in an effort to unburden start-up ventures and promote entrepreneurialism in the EU.
We do welcome the possible extension of the one-stop-shop (OSS) and, over time, of the import-one-stop-shop (IOSS), as these initiatives reduce administrative obligations through limiting required registrations and therefore help businesses. We encourage the Commission to consider the following transactions: E-Mobility, Consignment-stock, Toll-manufacturing requiring purchases and sales in another country than the country of establishment, deemed supply of goods (i.e., movement of own goods also covering obligations triggered by tooling and cross-border leasing).
Read full responseResponse to Fair taxation of the digital economy
15 May 2018
Tax Executives Institute, Inc., (TEI) commends the European Commission for providing the opportunity for stakeholders to comment on the Commission's efforts with respect to the fair taxation of the digital economy. TEI's comments are set forth in the letter accompanying this message as it exceeds the 4000 character maximum length. Please note the letter addresses both Commission proposals regarding the fair taxation of the digital economy, as well as providing general comments relevant to both proposals.
The attached letter was prepared by TEI’s European Direct Tax Committee, whose Chair is Giles Parsons. If you have any questions about the comments please contact Mr. Parsons at +44 (0)1455 826561, Parsons_Giles@cat.com, or Benjamin R. Shreck of TEI's legal staff, at +1 202 464 8353, bshreck@tei.org.
Read full responseResponse to Fair taxation of the digital economy
15 May 2018
Tax Executives Institute, Inc., (TEI) commends the European Commission for providing the opportunity for stakeholders to comment on the Commission's efforts with respect to the fair taxation of the digital economy. TEI's comments are set forth in the letter accompanying this message as it exceeds the 4000 character maximum length. Please note the letter addresses both Commission proposals regarding the fair taxation of the digital economy, as well as providing general comments relevant to both proposals.
The attached letter was prepared by TEI’s European Direct Tax Committee, whose Chair is Giles Parsons. If you have any questions about the comments please contact Mr. Parsons at +44 (0)1455 826561, Parsons_Giles@cat.com, or Benjamin R. Shreck of TEI's legal staff, at +1 202 464 8353, bshreck@tei.org.
Read full response