- The EESC supports the aim of the proposal and is pleased that the proposal for a directive enables Member States to react flexibly to fraud. However, the EESC points also to a number of shortcomings in the proposal.
- The EESC does have some concerns since the proposed procedure makes it practically impossible for a Member State's application for derogation from the common VAT system to be discussed by experts at a meeting of the committee.
- The introduction of the QRM could partially remove remaining barriers to the single market stemming from uncoordinated tax policy. Although, the EESC points out that the application of the QRM could also lead to considerable harm in relation to the tax receipts of some Member States.
- There is cause for concern about the possible loss of significant Member State powers in the field of taxation.
- The EESC notes that under, the measures intended to simplify the procedure for collecting VAT may not, except to a negligible extent, affect the overall amount of the tax revenue of the Member State collected at the stage of final consumption.
- The approval process should not rule out the possibility for a member of the committee to request the termination of the written procedure without result.
- The EESC also thinks, that Member States must have the opportunity, if necessary, to have a draft application for derogation discussed in advance in the advisory committee and so forestall possible proceedings before the European Court of Justice.