EU ViDA Platform Economy what’s next

Deemed Supplier, complex supply chains and Toms – lawmakers and marketplaces exchange views

The workshop fostered dialogue between tax administrations and the digital economy. Participants agreed that balanced input from both sides is essential to ensuring that the explanatory notes — expected in draft form by Q1 2026 — provide sufficient clarity and practical guidance for implementation across the EU. Businesses and Member States have been invited to submit further feedback within two weeks following the event.

Challenges around ViDA Pillar 2

1. Application of the deemed supplier model (DSM)

The workshop’s central theme was how to apply the DSM, under which online platforms may be treated as the supplier for VAT purposes when facilitating certain transactions (notably short-term accommodation and passenger transport). The discussion highlighted the tension between creating a level playing field and avoiding undue administrative burdens on smaller operators.

2. Roles and responsibilities of platforms

Participants examined the scope of platforms’ compliance duties, including record-keeping, invoicing, and VAT collection. Many called for clearer demarcation between platforms’ intermediary role and full VAT liability as deemed suppliers.

3. Interaction with Article 28 and TOMS

Complex overlaps between the DSM, Article 28 (agency relationships), and the Tour Operators Margin Scheme (TOMS)remain a key interpretative challenge. Some Member States questioned whether double taxation or inconsistent treatment could arise where platforms mediate in multi-party or chain transactions.

4. SME exemption and proportionality

Delegates discussed whether the small enterprise exemption under Article 284 could apply to platform operators acting as deemed suppliers. This raises questions about proportionality and the risk of competitive distortions if digital intermediaries are excluded.

5. Facilitation fees and Article 46a

The taxation of facilitation fees charged by platforms — and the interaction with new Article 46a clarifying place-of-supply rules — was identified as another technical area requiring explicit examples in the explanatory notes.

6. 2028 voluntary launch timing and implementing regulation

The workshop also addressed concerns about synchronising the adoption of implementing measures with national transposition timelines. Several Member States urged the Commission to ensure legal certainty well in advance of 2027, when ViDA’s platform reforms are expected to take effect.

Policy differences on Platform Economy reform

Debate was particularly animated around:

• Whether the deemed supplier model should be optional in specific cases;

• The dividing lines between the DSM, Article 28 and TOMS;

• Treatment of complex, multi-link or chain transactions;

• The broader interaction of the DSM with general VAT rules; and

• The need for transparency from Member States in applying uniform interpretations.

Next – completing explanatory notes early 2026

The Commission will now begin drafting the explanatory notes, taking into account the workshop’s findings and subsequent written feedback. A first draft is anticipated in early 2026, with continued consultation between Member States, businesses and VAT practitioners.

EU VAT in the Digital Age reforms