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EUCIS-LLL contribution to the Commission consultation on review of existing VAT legislation

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EUCIS-LLL welcomes the opportunity to contribute to the Commission consultation on the Review of existing VAT legislation on public bodies and tax exemptions in the public interest. While EUCIS-LLL recognises that VAT legislation on public bodies and tax exemptions in the public interest suffer some incoherencies across Member States – which may go against the requirements of a true single market – it would nevertheless like to bring to the Commission’s attention a number of concerns which its members have expressed about the likely negative impact that the removal of the VAT exemption would have on their activities. EUCIS-LLL is also sorry that the Commission only concentrates on the alleged obstacles that are the result of the exemptions of public bodies (Art. 13 of the VAT Directive) without referring to the positive aspects of these exemptions, for example the fact they enable public bodies to respond to the needs of all, namely the most vulnerable members of the population. This exemption is also in keeping with Protocol 26 on services of general interest, including the guarantee of high levels of quality, safety and affordability. In the context of these discussions, EUCIS-LLL sees an urgent need for special consideration to be given to the activities carried out by educational, cultural, sports for all and youth non-for-profit organisations which play an essential role at the local level in promoting and ensuring social inclusion among society’s potentially more vulnerable groups.

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