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The obvious questions are (1) why didn't they create something like VAT MOSS (or whatever they call the current version), and (2) why no de minimus?

I did some searching on Google, and its LLM gave what seemed to be a good summary of the reasons they did not do that. If anyone wants to see that here's the prompt [1].

It also said that they are scrambling to fix this up. Industry coalitions are pushing for something like VAT MOSS for this to be included the upcoming "Circular Economy Act" due later this year.

I followed up asking about using an intermediary, similar to how it is often done for dealing with sales tax in the US. Here's the prompt [2] if anyone wants to see that.

It gave a seemingly reasonable explanation of why that is much more difficult to do that it is for taxes.

[1...] Why didn't they create something similar for this to the VAT MOSS system (that is the old name...I think it is called something else now) they use for VAT which lets you register for VAT in just one country and remit you VAT collected for sales in all countries to that one country and that county's tax authorities deal with giving each country their share?

[1...] I'm seeing a lot of small businesses with low sales outside their home country getting really harmed by having to register in each country someone orders from.

[1] (Also, why no de minimus rule like I believe they have for VAT)?

[2...] With cross border tax issues (not so much in Europe because VAT is simple, but in the US for example where sales tax for online sales is a nightmare due to several thousand different taxing jurisdictions) a common solution is to have an intermediary that is the seller of record.

[2...] The transaction is structures so the intermediary buys from the vendor, and the customer buys from the intermediary. The first part is a B2B sale for resale which is usually sales tax exempt making it easy for the vendor. It is the intermediary that sells to the remote customer and deals with the tax nightmare.

2] Could something like that work with the Packaging and Packaging Waste Regulation? If the intermediary was in the same jurisdiction as the vendor, the vendor would only be shipping in country, so would only have to register with their own country. The intermediary would be the one that registers in every country.



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