On 15 October 2025, ETAF responded to the public consultation of the European Commission on the upcomig legislative VAT package on travel and tourism.
ETAF welcomes this initiative to modernise the VAT rules for the travel and tourism sector, as the current framework is outdated and inconsistent with the realities of today’s digital and globalised economy.
ETAF considers that the Tour Operators’ Margin Scheme (TOMS) no longer meets its original objectives, creates legal uncertainty and distorts competition due to its divergent interpretation across Member States. The current rules impair VAT neutrality, especially for business customers and unfairly disadvantage EU-established travel agents compared to non-EU operators supplying EU destination travel services. ETAF would therefore support a reform that clarifies TOMS' scope and limits it to B2C supplies, excludes MICE activities and other B2B transactions.
Regarding passenger transport, ETAF notes that the existing patchwork of VAT treatments between transport modes in Member States leads to complexity, compliance burdens and distortions. ETAF supports greater harmonisation, clearer definitions and the alignment of VAT policy with the EU’s environmental and competitiveness goals, ensuring neutrality and fairness across all transport modes while simplifying compliance for cross-border operators.
