CFE risponde alla consultazione della Commissione UE su IVA ed economia circolare: regime del margine per beni usati e rigenerati, donazione e distruzione di beni ancora utilizzabili, detrazione IVA sulle autovetture.
Response to the Commission consultation
CFE Tax Advisers Europe has published an Opinion Statement answering the European Commission consultation on VAT and the circular economy, submitted on 4 November 2026. CFE supports efforts to make the VAT framework better suited to circular business models. It stresses that reforms should be clearer and more workable for businesses, while still allowing tax administrations to verify transactions effectively.
Used, refurbished and remanufactured goods
CFE points to several practical problems in the VAT margin scheme. Buyers struggle to verify a seller's VAT status, the definition of second-hand goods and of a taxable dealer is uncertain, mixed consignments in cross-border sales raise questions, and costs charged separately from the price are treated unclearly. CFE asks for clearer guidance on the evidence dealers can rely on and for better verification tools, such as a public mechanism to check sellers' VAT status.
It also suggests considering an EU-wide or interoperable register that lets buyers check whether the margin scheme applies, possibly feeding the data into standardised e-invoices. CFE further recommends reviewing the rules on imported works of art, collectors' items and antiques, so that the taxable margin does not exceed the dealer's real commercial margin merely because of a reduced valuation at import.
Donation and destruction of viable goods
In CFE's view, VAT rules should not discourage businesses from donating or reusing goods that would otherwise be discarded. It recommends exploring clearer and more harmonised EU rules, including whether favourable treatment should go beyond food donations to other usable goods. Options outside the VAT system should be assessed alongside any VAT changes.
VAT deduction on passenger cars
CFE recommends considering greater harmonisation of national deduction rules, balancing environmental objectives with the principle of VAT neutrality. Any extension of deduction rights should come with clear and proportionate rules on later private use, covering acquisition costs, depreciation and operating expenses.
Legal certainty and workability
Overall, CFE argues that reform should improve legal certainty, cut unnecessary administrative burdens and keep VAT rules practical as circular business models develop.
Fonte: CFE Tax Advisers Europe