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EU VAT on voucher reforms January 2019

From 1 January 2019, the 27 member states of the EU adopted harmonised rules on the VAT treatment of single-use and multi-use retail vouchers. These reforms are enacted by the VAT COUNCIL DIRECTIVE amending Directive 2006/112/EC as regards the treatment of vouchers

A voucher is a instrument used as consideration or payment for the supply of goods or services. For VAT purposes, the EU as defined vouchers into two models. Follow all the European Union’s completed and planned reforms via VAT Calc’s EU VAT reform tracker.

1 Single Use Voucher

These are vouchers where the shop or provider where the voucher may be redeemed is set and the goods or services and country of use are known (so VAT rate clear) at the time of buying the voucher.  For example, a voucher issued by a single national chain may typically only be used in shops of that chain. So it is defined at the time of buying the voucher who the supplier will be. This is therefore deemed supply. Any VAT due on those underlying goods or services is paid at the point of issue of the voucher and at the point of each transfer of it, where these are done for consideration

2 Multi-purpose voucher

These are vouchers where the goods or services, shop, provider or jurisdiction where the voucher may be redeemed is not set at the time of buying the voucher.  Typically, this is a scheme with a number of differing retailers signed-up, and the consumer may redeem the voucher in any one of the stores for products or services that may have different VAT rates. So it is not clear who the supplier will be or what VAT rate at the time of buying the voucher. Any VAT due is only payable when the voucher is redeemed for goods or services. The consideration for that supply will be amount last paid for the voucher or, in the absence of this information, its face value.

The new EU rules cover:

  • The rules will exclude discount vouchers, transport tickets, admission tickets and postage stamps.
  • the definition of vouchers, including: retailer gift cards; price discount coupons; and pre-paid voice and data telephony cards.
  • the different treatments of single and multiple use vouchers, and the place of supply. It seeks to avoid double taxation where vouchers are used across countries with varying VAT rules – termed mismatches.
  • how to determine the taxable base of vouchers to calculate the VAT due.
  • It does not cover discount vouchers which allow for a price reduction, but carry no right to receive goods or services

EU VAT reforms

Reform (click for details) Update
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2030? Digital Reporting Requirements and e-invoicing harmonisation Likely delay to 2030
Structured e-invoices supercede paper invoices Likely delay to 2030
EC Sales lists replaced by Digital Reporting Requirements Likely delay to 2030
2028 EU Customs reforms Published May 2023
€150 import consignment threshold removed Published May 2023
2026 DAC8 harmonised crypto asset reporting Approved May 2023
2025 VAT registration thresholds equivalence foreign businesses 1 Jan 2025
Virtual events VAT rule changes 1 Jan 2025
Single VAT Registration in the EU - extension of OSS Likely delay to 2026
Marketplace deemed supplier extended to EU sellers Likely delay to 2026
Proposal for VAT treatment of the platform economy Likely delay to 2026
EU IOSS mandated for marketplaces Likely delay to 2026
Call-off stock VAT simplification ends Likely delay to 2026
Harmonisation of B2B Reverse Charge rules Likely delay to 2026
Financial Services VAT exemption reform proposals Consultation complete; proposal awaited
Tour operator margin scheme VAT reforms EC undertaking fresh review
2024 Payment providers' seller transaction reporting and bookkeeping obligations In effect since 1 Jan 2024
2023 DAC 7 - marketplace reporting harmonisation In effect since 1 Jan 2024
2022 IOSS reforms to prevent double taxation On hold
EU reduced VAT rate freedoms Entered into force 6 April 2022
VAT in the Digital Age proposals Published Dec 2022
EU DAC8 cryptocurrency tax reporting proposals Published Dec 2022
VAT Gap Initiative Q3 2022
EU Definitive VAT System On hold
2021 One-Stop-Shop (OSS) single EU VAT return In effect since 1 July 2021
Ending €22 import VAT exemption; new IOSS return In effect since 1 July 2021
Marketplace deemed supplier EU VAT reforms In effect since 1 July 2021
2020 EU four Quick Fixes for VAT In effect
Tax authorities anti-VAT fraud cooperation In effect
Tax Action Plan - 25 VAT and other tax reforms roadmap See 'VAT in the Digital Age' and others
2019 Simplification of e-services VAT compliance and thresholds In effect
Single and multi-use vouchers In effect
2018 Lower e-book and publications VAT rates In effect, although not all EU states have adopted the option

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