Split Payment across the European Union – Review and Analysis

In this article, the author discusses the split-payment mechanisms either implemented or drafted among the EU Member States. In principle, there are two basic ways to implement such a mechanism: (i) a VAT account scheme (implemented in Poland and Romania, as well as in pre-accession Bulgaria); and (ii) a VAT withholding scheme (drafted in France and the United Kingdom). Mixed mechanisms also appear (in Italy and the Czech Republic). In the opinion of the author, the VAT withholding mechanism might be the best way to implement split payment.