Qualitative Assessment of Two Recent EU Commission Proposals to Impose (More) VAT Obligations on Platforms

The VAT e-commerce package entered into application on 1 July 2021. It imposed new obligations on e-commerce platforms, including VAT liability and record-keeping obligations with respect to underlying transactions. In December 2022 and May 2023, the European Commission adopted a series of proposals that are meant to already adjust or significantly broaden the scope of these obligations. In addition, new obligations are proposed concerning platforms that facilitate short-term accommodation rental and passenger transport services. In this article, the authors seek to assess the expected impact of the proposed rules and to determine to what extent the compliance burden and associated risks would be increased as compared to the situation as it stands since 2021.