eu travel tech

January 2026 1 eu travel tech Position Paper – EU Taxation Simplification Executive Summary The European Commission’s Competitiveness Compass rightly identifies regulatory simplification as a key enabler of European competitiveness. eu travel tech supports this objective and believes EU taxation policy must adopt a coherent, proportionate, data - d riven framework that avoids duplication, fragmentation and unnecessary administrative burden. Overlapping reporting and withholding regimes have created an inefficient compliance environment for digital travel platforms and their predominantly SME partners. Multiple EU initiatives and national measures rely on the same transactional data while impo sing separate obligations, reducing legal certainty and diverting resources without delivering equivalent compliance benefits.

…obligations, reducing legal certainty and diverting resources without delivering equivalent compliance benefits. eu travel tech therefore calls for a harmonised EU data regime, with data collected once and usable for all relevant taxes. Where authorities already receive sufficient information, additional regimes should not be layered on top. In particular, withholdin g tax regimes should not be introduced where existing data allows effective collection, and additional digital services reporting obligations should be avoided where authorities already possess the necessary information. This proportionality principle shou ld guide related measures. For short - term rentals, DAC7, ViDA reporting, and electronic invoicing already enhance visibility. Additional mechanisms, such as deemed supplier rules, should only be introduced if they clearly add value.

…visibility. Additional mechanisms, such as deemed supplier rules, should only be introduced if they clearly add value. Similarly, Digital Services Taxes (DSTs) create fragmentation and multiple taxation, particularly for cross - border travel services. DSTs add complexity, increase compliance costs, and distort competition without clear benefits. Further DST measures should be avoided in favor of coordinated, data - driven solutions addressing genuine tax imbalances. Overall, the regulatory burden on platforms has become unduly costly and disproportionate, adding limited value for tax authorities and risking EU competitiveness.

…has become unduly costly and disproportionate, adding limited value for tax authorities and risking EU competitiveness. The 2026 EU Tax Simplification package offers a unique opportunity to rationalise EU tax data requirements, eliminate duplication, and embed a streamlined, data - driven approach that enables effective tax collection while reducing unnecessary burdens for compliant busi nesses. Such a simplification would enhance the competitiveness of a crucial dri ver of the European economy; the tourism industry. Ref. Ares(2026)1785596 - 17/02/2026 January 2026 2 1. Introduction The European Commission’s Competitiveness Compass, presented in January 2025, sets simplification of EU regulation as one of the enablers of European competitiveness across all sectors. eu travel tech welcomes the intention to address regulatory complexiti es, overlaps and fragmentation.

…all sectors. eu travel tech welcomes the intention to address regulatory complexiti es, overlaps and fragmentation. Today, up to 30% of EU tech companies’ resources can be taken up by compliance, according to data from EU tech companies. This percentage will only increase with additional compliance requirements being placed on tech companies such as the three pillars of ViDA. While resources invested in compliance are resources well spent, resources spent to comply with increased (duplicative) reporting could be dedicated to actually addressing issues being reported on to the benefit of travelers or SMEs. We strongly believe in smart regulation and, in our view, there is an opportunity to streamline regulation, thus also creating the conditions to deliver more effectively the desired policy outcomes.

…to streamline regulation, thus also creating the conditions to deliver more effectively the desired policy outcomes. In the area of taxation, we note that DAC7, ViDA (three pillars ), CESOP and DSA have tried to tackle tax gaps and/or increase transparency in business user activity from different perspectives, introducing reporting requirements or collect and remit oblig ations that duplicate or conflict with one another, making compliance complex and creating significant administrative burdens for reporting platforms but also reportable businesses which are in their majority micro or SMEs. At the same time, diverging nati onal rules and lack of uniform enforcement reduce legal certainty and increase compliance burdens.

…time, diverging nati onal rules and lack of uniform enforcement reduce legal certainty and increase compliance burdens. The European tax landscape is already fragmented due to the different national DSTs, which have introduced substantial complexity for regional and global businesses, including European companies. While these measures were initially intended as temporary, t hey have become an ongoing source of inequity and double taxation, creating distortions in cross - border trade and investment. Introducing additional national or EU - level rules would risk exacerbating these issues, rather than resolving them. Even an EU - wid e measure, although theoretically capable of reducing fragmentation, could still fail to achieve genuine harmonisation and might perpetuate inequities and double taxation concerns.

…could still fail to achieve genuine harmonisation and might perpetuate inequities and double taxation concerns. For these reasons, further DST - related measures should not be pursued; inst ead, efforts should focus on eliminating distortions and preventing unintended cost increases for compliant businesses and consumers. As policy - makers are working towards a Tax Simplification package in 2026, we believe this is a unique opportunity to address the concerns raised above. eu travel tech is available to provide further input to the discussions based on our experience with le gislation in practice. 2. Digital Services Taxes Digital Services Taxes (DST) have been introduced in a number of Member States as a temporary measure pending an agreement at global level.

(DST) have been introduced in a number of Member States as a temporary measure pending an agreement at global level. As the implementation of the January 2026 3 global solution through the OECD is in doubt, the risk of similar measures proliferating around Europe is increasing. An even more fragmented European landscape in this area will only add complexities in what is already a hugely problematic measure. Existing DSTs were designed to address the perceived “unfair” global distribution of taxation of the largest digital businesses in anticipation of the implementation of Pillar 2 of the OECD. However, to avoid the application of global tax treaties, the DST s were implemented as an additional tax on top of the existing corporate taxation framework.

…tax treaties, the DST s were implemented as an additional tax on top of the existing corporate taxation framework. DSTs were implemented as a temporary measure but have now clear lived beyond their temporary character and start to influence the competitiveness of international markets due to its double, triple an d in some cases quadruple taxation of the same transaction. . Advertising markets only get taxed once (where the user clicks the ad) but in the travel industry both the country of the traveller as well as the country of the destination (hotel) want to tax the same transaction. The travel industry, due to its lower pr ofit margins than advertising, is the only industry where this unintended consequence is applicable and is so hard felt. National DSTs thus result in multiple taxation of one and the same transaction.

…is applicable and is so hard felt. National DSTs thus result in multiple taxation of one and the same transaction. This is especially the case for travel services, which are inherent international. For example, a French booker books a boat tour in Spain but such inventory is supplied by Musement (an Italy based aggregator). In this example, DST would need to be paid in Italy (given that the aggregator supplying the invento ry is based in Italy), in addition to paying DST in France and/or Spain. The uncoordinated nature of national DSTs also has an impact on the tax revenue of home - countries of European businesses in scope. In addition, national DSTs penalise online platform business models in comparison to direct online distribution models, something that is also observed in other areas of EU law e.g. the DSA.

…comparison to direct online distribution models, something that is also observed in other areas of EU law e.g. the DSA. For example, hotel chains do not have to pay the tax because they are considered traditional retailers; thus prices offered by eu travel tech members would be higher than hotels’ direct prices if the DST is added on top of indirect transactions, which puts platform business models at a competitive disadvantage. This is particularly relevant since global hotel chains (and retailers beyond the travel sector) operate very similarly to online platforms (e.g. not owning and operating properties themselves, but providing brand, marketing and tech solutions to franchisees). 3.

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originalus šaltinis (PDF) ↗

January 2026 1 eu travel tech Position Paper – EU Taxation Simplification Executive Summary The European Commission’s Competitiveness Compass rightly identifies regulatory simplification as a key enabler of European competitiveness. eu travel tech supports this objective and believes EU taxation policy must adopt a coherent, proportionate, data - d riven framework that avoids duplication, fragmentation and unnecessary administrative burden. Overlapping reporting and withholding regimes have created an inefficient compliance environment for digital travel platforms and their predominantly SME partners. Multiple EU initiatives and national measures rely on the same transactional data while impo sing separate obligations, reducing legal certainty and diverting resources without delivering equivalent compliance benefits.

…obligations, reducing legal certainty and diverting resources without delivering equivalent compliance benefits. eu travel tech therefore calls for a harmonised EU data regime, with data collected once and usable for all relevant taxes. Where authorities already receive sufficient information, additional regimes should not be layered on top. In particular, withholdin g tax regimes should not be introduced where existing data allows effective collection, and additional digital services reporting obligations should be avoided where authorities already possess the necessary information. This proportionality principle shou ld guide related measures. For short - term rentals, DAC7, ViDA reporting, and electronic invoicing already enhance visibility. Additional mechanisms, such as deemed supplier rules, should only be introduced if they clearly add value.

…visibility. Additional mechanisms, such as deemed supplier rules, should only be introduced if they clearly add value. Similarly, Digital Services Taxes (DSTs) create fragmentation and multiple taxation, particularly for cross - border travel services. DSTs add complexity, increase compliance costs, and distort competition without clear benefits. Further DST measures should be avoided in favor of coordinated, data - driven solutions addressing genuine tax imbalances. Overall, the regulatory burden on platforms has become unduly costly and disproportionate, adding limited value for tax authorities and risking EU competitiveness.

…has become unduly costly and disproportionate, adding limited value for tax authorities and risking EU competitiveness. The 2026 EU Tax Simplification package offers a unique opportunity to rationalise EU tax data requirements, eliminate duplication, and embed a streamlined, data - driven approach that enables effective tax collection while reducing unnecessary burdens for compliant busi nesses. Such a simplification would enhance the competitiveness of a crucial dri ver of the European economy; the tourism industry. Ref. Ares(2026)1511766 - 10/02/2026 January 2026 2 1. Introduction The European Commission’s Competitiveness Compass, presented in January 2025, sets simplification of EU regulation as one of the enablers of European competitiveness across all sectors. eu travel tech welcomes the intention to address regulatory complexiti es, overlaps and fragmentation.

…all sectors. eu travel tech welcomes the intention to address regulatory complexiti es, overlaps and fragmentation. Today, up to 30% of EU tech companies’ resources can be taken up by compliance, according to data from EU tech companies. This percentage will only increase with additional compliance requirements being placed on tech companies such as the three pillars of ViDA. While resources invested in compliance are resources well spent, resources spent to comply with increased (duplicative) reporting could be dedicated to actually addressing issues being reported on to the benefit of travelers or SMEs. We strongly believe in smart regulation and, in our view, there is an opportunity to streamline regulation, thus also creating the conditions to deliver more effectively the desired policy outcomes.

…to streamline regulation, thus also creating the conditions to deliver more effectively the desired policy outcomes. In the area of taxation, we note that DAC7, ViDA (three pillars ), CESOP and DSA have tried to tackle tax gaps and/or increase transparency in business user activity from different perspectives, introducing reporting requirements or collect and remit oblig ations that duplicate or conflict with one another, making compliance complex and creating significant administrative burdens for reporting platforms but also reportable businesses which are in their majority micro or SMEs. At the same time, diverging nati onal rules and lack of uniform enforcement reduce legal certainty and increase compliance burdens.

…time, diverging nati onal rules and lack of uniform enforcement reduce legal certainty and increase compliance burdens. The European tax landscape is already fragmented due to the different national DSTs, which have introduced substantial complexity for regional and global businesses, including European companies. While these measures were initially intended as temporary, t hey have become an ongoing source of inequity and double taxation, creating distortions in cross - border trade and investment. Introducing additional national or EU - level rules would risk exacerbating these issues, rather than resolving them. Even an EU - wid e measure, although theoretically capable of reducing fragmentation, could still fail to achieve genuine harmonisation and might perpetuate inequities and double taxation concerns.

…could still fail to achieve genuine harmonisation and might perpetuate inequities and double taxation concerns. For these reasons, further DST - related measures should not be pursued; inst ead, efforts should focus on eliminating distortions and preventing unintended cost increases for compliant businesses and consumers. As policy - makers are working towards a Tax Simplification package in 2026, we believe this is a unique opportunity to address the concerns raised above. eu travel tech is available to provide further input to the discussions based on our experience with le gislation in practice. 2. Digital Services Taxes Digital Services Taxes (DST) have been introduced in a number of Member States as a temporary measure pending an agreement at global level.

(DST) have been introduced in a number of Member States as a temporary measure pending an agreement at global level. As the implementation of the January 2026 3 global solution through the OECD is in doubt, the risk of similar measures proliferating around Europe is increasing. An even more fragmented European landscape in this area will only add complexities in what is already a hugely problematic measure. Existing DSTs were designed to address the perceived “unfair” global distribution of taxation of the largest digital businesses in anticipation of the implementation of Pillar 2 of the OECD. However, to avoid the application of global tax treaties, the DST s were implemented as an additional tax on top of the existing corporate taxation framework.

…tax treaties, the DST s were implemented as an additional tax on top of the existing corporate taxation framework. DSTs were implemented as a temporary measure but have now clear lived beyond their temporary character and start to influence the competitiveness of international markets due to its double, triple an d in some cases quadruple taxation of the same transaction. . Advertising markets only get taxed once (where the user clicks the ad) but in the travel industry both the country of the traveller as well as the country of the destination (hotel) want to tax the same transaction. The travel industry, due to its lower pr ofit margins than advertising, is the only industry where this unintended consequence is applicable and is so hard felt. National DSTs thus result in multiple taxation of one and the same transaction.

…is applicable and is so hard felt. National DSTs thus result in multiple taxation of one and the same transaction. This is especially the case for travel services, which are inherent international. For example, a French booker books a boat tour in Spain but such inventory is supplied by Musement (an Italy based aggregator). In this example, DST would need to be paid in Italy (given that the aggregator supplying the invento ry is based in Italy), in addition to paying DST in France and/or Spain. The uncoordinated nature of national DSTs also has an impact on the tax revenue of home - countries of European businesses in scope. In addition, national DSTs penalise online platform business models in comparison to direct online distribution models, something that is also observed in other areas of EU law e.g. the DSA.

…comparison to direct online distribution models, something that is also observed in other areas of EU law e.g. the DSA. For example, hotel chains do not have to pay the tax because they are considered traditional retailers; thus prices offered by eu travel tech members would be higher than hotels’ direct prices if the DST is added on top of indirect transactions, which puts platform business models at a competitive disadvantage. This is particularly relevant since global hotel chains (and retailers beyond the travel sector) operate very similarly to online platforms (e.g. not owning and operating properties themselves, but providing brand, marketing and tech solutions to franchisees). 3.

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originalus šaltinis (PDF) ↗

…eu travel tech position paper – VAT in the digital age The short -term rental (STR) market is among the most dynamic aspects of Europe’s tourism sector today. Over the past years, STRs have come to revolutionize the way many Europeans travel. Platforms engaged in the intermediation of STRs have played a significant role in the trend, providing cons umer transparency and convenience to an otherwise opaque market. This has benefited both consumers and many STR hosts. eu travel tech recognizes the need to adjust and modernize EU tax legislation in light of these developments . A step in this direction wa s taken with the 7 th revision of the Directive on Administrative Cooperation and the Central Electronic System of Payment Information .

…7 th revision of the Directive on Administrative Cooperation and the Central Electronic System of Payment Information . Our members full y support the objective of combating tax fraud and are committed to supporting authorities in the enforce ment of VAT legislation wherever reasonable . Nonetheless , we are concerned about certain elements of the VAT in the digital age (ViDA) package of proposals as presented by the European Commission , particularly the VAT deemed supplier regime and its possible application to platform s active in the STR market and passenger transport services . The proposed regime would introduce significant compliance costs, negatively affect VAT and STR channel neutrality and disproportionately impact SMEs and consumers engaged in the rental of short - term accommodation.

…neutrality and disproportionately impact SMEs and consumers engaged in the rental of short - term accommodation. eu travel tech wishes to be a constructive partner to policymakers, facilitating the development of legislation which is proportionate and fit for purpose. This paper is thus split in two sections : firs tly ,we outline our general views on the concept and justification of the deemed supplier regime and second, we raise concrete issues we have identified in the proposals of the ViDA package that we believe would benefit from clarification and improvement. While this paper focuses on STR services, the views outlined below also apply in relation to passenger transport services.

…this paper focuses on STR services, the views outlined below also apply in relation to passenger transport services. General views on the deemed supplier regime for STR and passenger transport Substantiating justification for the proposals eu travel tech has strong concerns over the premises and specific aspects of the underlying analyses conducted in the context of the ViDA initiative, particularly regarding the deemed supplier regime applicable to STR and passenger transport . We believe the proposed deemed supplier regime is not fit to satisfy the basic policy objectives set out for this package of measures 1 . There is a need for further transparency regarding the study conducted on the platform economy 2.

…of measures 1 . There is a need for further transparency regarding the study conducted on the platform economy 2. In particular, regarding STR platforms, we are concerned that the study posits that only 62 accommodation platforms would be impacted 3 by the deemed supplier 1 Specific policy objectives of the ViDA package: 1. Improve reporting requirements to unlock the opportunities provided by digitalization, 2. Promote convergence and interoperability of IT systems, 3. Create a level-playing field for businesses, regardless of the business model, 4. Reduce burdens, regulatory fragmentation and associated costs, 5. Minimise the need for multiple VAT registrations in the EU; SWD(2022) 393 final, p. 34 2 VAT in the Digital Age - Final Report – Volume 2: The VAT treatment of the platform economy, DG TAXUD, 2022 3 VAT in the Digital Age – VAT treatment of the platform economy (Volume 2), p.

…of the platform economy, DG TAXUD, 2022 3 VAT in the Digital Age – VAT treatment of the platform economy (Volume 2), p. 38 Ref. Ares(2023)2389800 - 03/04/2023 2 regime, while the sector itself believes the number is much higher . Indeed, the European Commis sion’s own impact assessment posits a number of ca. 710 STR platforms active in the EU. 4 We are also concerned that the study and impact assessment do not include an estimate of the number of underlying providers who are likely to attain a VAT ID , as their output will become subject to VAT and accommodation platforms who are not able to cope with the additional burden of the regime will push their suppliers to attain such VAT IDs.

…who are not able to cope with the additional burden of the regime will push their suppliers to attain such VAT IDs. This would lead to a significant additional burden on tax authorities ac ross the EU , as the audit population would experience an inflow of additional taxpayers, who would be able to claim input VAT on certain costs 5, thus hollowing out a potential significant proportion of envisaged additional revenue . The study further lacks an in -depth investigation into the reasons for STR ’s lower prices when compared to traditional hotels, which may not be the result of VAT treatment but rather the dynamics of the STR sector ( e.g. difference in services provided additional to accommodation , requiring little to no staff or additional facilities). The introduction of an extended deemed supplier regime as proposed by the Commission raises questions as to its proportionality .

…of an extended deemed supplier regime as proposed by the Commission raises questions as to its proportionality . The proposed extension of the deemed supplier regime a nd technical complications that it would entail are expected to trigger the need for major adjustments from platforms and underlying suppliers, disrupting business operations. It is worth examining whether the alleged additional VAT income for tax authorit ies and the additional administrative and compliance burdens for businesses justify the switch to a different system. Safeguarding Neutrality The European Commission has set out the creation of “a level -playing field for businesses, regardless of the business model” 6 as a key policy objective for the ViDA initiative. eu travel tech is concerned that the proposed deemed supplier regime would not serve this objective .

ViDA initiative. eu travel tech is concerned that the proposed deemed supplier regime would not serve this objective . The proposed STR deemed supplier regime would have a significant distortive effect regarding STR services provided by small businesses or private persons subject to SME VAT exemptions commonly set in many Member States. In these cases, the deemed supplier regime would effectively dismantle the SME exemption if the STR service is intermediated by a platform. However, such exemptions would continue to apply if the STR service is not inte rmediated, but offered directly through a website owned by the STR host or even an offline transaction.

…is not inte rmediated, but offered directly through a website owned by the STR host or even an offline transaction. This is contrary to arguments that the proposal would address ”an unjustified distortion of competition between supplies performed through online platfo rms that escape VAT taxation, and supplies performed in the traditional 4 SWD(2022) 350 final, p. 168; we also wonder whether the approx. 700 online travel agents that have been identified as part of (ongoing) the Travel & Tourism Study (mainly acting as disclosed intermediaries) have been considered. 5 This issue has already been raised by the French authorities in their response to the open public consultation on the ViDA initiative 6 Staff Working Document – Impact Assessment report (SWD (2022) 393 final), p. 35 3 economy that are subject to VAT ” 7 .

Staff Working Document – Impact Assessment report (SWD (2022) 393 final), p. 35 3 economy that are subject to VAT ” 7 . In fact, the deemed supplier regime would create just the reverse distortion between online platforms and the traditional economy, thereby eliminating the existing VAT level -playing field between offers sold directly by STR hosts and those intermediated by platforms . As mentioned in OECD guidance: “there is no one - size - fits - all s olution, taxing jurisdictions are encouraged to ensure an equal treatment of various distribution channels in a given market, be they traditional or digital” 8 .

…to ensure an equal treatment of various distribution channels in a given market, be they traditional or digital” 8 . The discrimination effect grows stronger when also considering that the services of the under lying suppliers (now captured by the proposed deemed supplier rules) would be subject to VAT but these same suppliers, who are predominantly micro - or small businesses, will not be able to deduct input VAT on the costs related to these services. In contras t, their bigger competitors, who are already liable to VAT, will continue to benefit from input VAT deductions, therefore compromising the principle of VAT neutrality while putting those SMEs at a disadvantage . Having in mind that the European Commission seeks to support and strengthen the position of micro -businesses and SMEs, it seems that the ViDA proposal would have a perverse effect on the objective pursued.

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originalus šaltinis (PDF) ↗