Proposal for a Council Directive amending Directive 2006/112/EC as regards the VAT treatment of financial and insurance services
Date: 2021-09-09
Institutions: Directorate-General for Taxation and Customs Union, European Commission
Subjects: common tariff policy, fiscal policy

EUROPEAN COMMISSION 
DIRECTORATE-GENERAL 
TAXATION AND CUSTOMS UNION 
Indirect Taxation and Tax Administration 
Value added tax 

Public consultation ‘VAT rules for 
financial and insurance services today 
and tomorrow’ 

Factual summary report 

Commission européenne/Europese Commissie, 1049 Bruxelles/Brussel, BELGIQUE/BELGIË - Tel. +32 22991111 
Office: SPA3 05/112 - Tel. direct line +32 229-62466 

Pia.Michelsen@ec.europa.eu 

 
 
 
 
 
 
1. 

INTRODUCTION, BACKGROUND 

The  current  VAT  rules  for  financial  and  insurance  services  suffer  a  number  of 
shortcomings.  They  are  complex,  difficult  to  apply  and  have  not  kept  pace  with  the 
development of new services in the sector, leading to a lack of VAT neutrality as well 
as legal uncertainty and high administrative and regulatory costs for businesses.  

The Commission ran a public consultation between 8 February and 3 May 2021 with 
the objective to gather the views of stakeholders and public authorities of the Member 
States  on  the  current  VAT  rules  for  financial  and  insurance  services  and  their 
functioning as well as on possible changes to these rules.  

The  consultation  followed  the  combined  evaluation  roadmap  and  Inception  Impact 
Assessment published in October 2020 and is the first stage of the process intended 
to modernise the EU VAT rules applicable to financial and insurance services. 

The  evidence  gathered  through  this  consultation  should  allow  evaluating  the  current 
rules on the one hand and shaping the options for review of the relevant provisions of 
the  VAT  Directive  on  the  other  hand,  both  in  view  of  a  possible  future  legislative 
proposal.  This  includes  the  collection  of  data  confirming  the  main  issues  under  the 
current rules. 

VAT rules for financial and insurance services are relevant for private and public sector 
stakeholders alike. The public consultation was therefore addressed to a large diversity 
of  stakeholders:  businesses,  consultancies,  representative  organisations  and  public 
authorities  of  Member  States  (such  as  tax  authorities).  Equally,  contributions  from 
academics, researchers, non-governmental  organisations and  the  general public were 
welcome.   

The consultation took the form of an online questionnaire. It did not aim at obtaining 
responses  statistically  representative  of  the  European  population  or  of  the  economic 
sector, thus the outcomes of the consultation cannot be extrapolated as scientifically 
representing its views. Respondents were not required to answer all the questions. The 
statistics  computed  in  this  summary  are  based  only  on  contributions  to  the  public 
consultation submitted through the online questionnaire. 

2 

 
2.  RESULT OF THE CONSULTATION 

The  questionnaire  included  closed  questions  (i.e.  questions  with  a  predetermined 
number  of  options  for  responses)  and  open  questions.  (i.e.  questions  with  text  fields 
allowing respondents to provide free input). The focus of this report is on the graphical 
analysis of responses to the closed questions.  

It  should  from  the  outset  be  noted  that  a  large  number  of  respondents  provided 
identical or very similar responses  to the questionnaire, giving reason to believe  that 
they formed part of a co-ordinated campaign. This presumption is based on the near 
concordance  of  responses  to  both  closed  questions  and  open  questions  and  on  the 
coincidental geographical location of respondents (namely Austria).  

In  order  to  identify  the  supporters  of  the  co-ordinated  campaign,  as  a  first  indicator, 
responses to open questions (i.e. questions 16, 23, 25, 27, 30, 33, 42, 45, 47, 48, 55, 
57,  59,  61  and  62)  have  been  compared.  Amongst  the  respondents  identified,  the 
wording  used  in  reply  to  e.g.  question  23  varied,  if  at  all,  only  slightly  due  to 
differences in use of capital letters, mistyping, the use of abbreviations or similar. The 
second  indicator  when  identifying  the  campaign  was  the  geographical  location  of 
respondents, being set exclusively in Austria.  

This report provides a graphical analysis of all contributions to the public consultation 
received  and,  where  appropriate  (i.e.  where  campaign  data  deviate  significantly  from 
the overall data), also a graphical analysis of contributions excluding those stemming 
from the campaign. Reference to data linked to the co-ordinated campaign can also be 
found in the respective footnotes.  

3 

 
2.1.  Number and distribution of replies –  
characteristics of respondents 

The public consultation received a considerable level of interest from a wide range of 
individuals  and  organisations  across  the  EU  (plus  nine  from  the  United  Kingdom  and 
two from the United States). In total, 469 replies were received, of which at least 271 
(i.e. 57.8% of all contributions) were identified as part of the co-ordinated campaign. 
51  respondents  uploaded  position  papers  in  addition  to  their  replies  to  the 
questionnaire.1 

The figures in this chapter display the distribution of replies and the characteristics of 
respondents. 

Figure 1: Total distribution of respondents  

1  

The distribution of type of respondents amongst those who provided a position paper is as follows: Business 
association (35), Company/business organisation (11), Consumer organisation (1), EU citizen (2) and Other (2). 
None of these respondents forms part of the presumed campaign.  

4 

 
 
 
 
 
                                              
Figure 2.1: Country of origin (Question 12) overall 

Figure 2.2: Country of origin (Question 12) excluding the presumed campaign 2 

Country of origin

Austria (47)
Denmark (2)
Hungary (2)
Luxembourg (4)
Romania (1)
United kingdom (9)

Belgium (22)
Finland (2)
Ireland (2)
Malta (1)
Slovakia (2)
United states (2)

Bulgaria (1)
France (11)
Italy (11)
Netherlands (8)
Spain (5)

Croatia (1)
Germany (44)
Latvia (3)
Poland (2)
Sweden (4)

Czechia (7)
Greece (1)
Lithuania (2)
Portugal (1)
Switzerland (1)

2   All 271 respondents forming part of the presumed campaign indicated to be located in Austria. 

5 

 
  
 
                                              
Figure 3.1: Type of respondent (Question 2) overall 

Figure 3.2: Type of respondent (Question 2) excluding the presumed campaign3 

I am giving my contribution as

9,10%

0,50%

0,50%

15,70%

0,50%

43,40%

36,90%

Business association (73)
Consumer organisation (1)
Non-EU citizen (1)
Trade union (1)

Company/business organisation (86)
EU citizen (31)
Other (18)

3  

The  distribution  of  organisation  size  concerning  respondents  forming  part  of  the  presumed  campaign  is  as 
follows: Business association (21), Company/business organisation (155), Consumer organisation (3), EU citizen 
(79) and Other (13). 

6 

 
 
 
 
                                              
Figure 4.1: Organisation size (Question 10) overall 

Figure 4.2: Organisation size (Question 10) excluding the presumed campaign4 

Organisation size

3,30%

16,20%

12,60%

17,20%

23,70%

Large (250 or more) (60)

Medium (50 to 249 employees) (25)

Micro (1 to 9 employees) (47)

Small (10 to 49 employees) (34)

No Answer (32)

Figure 5.1: Main activity (Question 15) overall 

4  

The  distribution  of  organisation  size  amongst  respondents  forming  part  of  the  presumed  campaign  is  as 
follows:  ‘Large  (250  or  more)’  (20),  ‘Medium  (50  to  249  employees)’  (7),  ‘Micro  (1  to  9  employees)’  (154), 
‘Small (10 to 49 employees)’ (11), ‘No Answer’ (79). 

7 

 
 
 
 
                                              
Figure 5.2: Main activity (Question 15) excluding the presumed campaign5 

What is your main activity?

13,60%

56,60%

21,70%

3,00%

5,10%

Both financial and insurance services (27) Mainly financial services (43)
Mainly insurance services (6)
No Answer (112)

Other services (10)

Figure 6: Main sector (Question 17) 

5  

The  distribution  of  the  main  activity  amongst  respondents  forming  part  of  the  presumed  campaign  is  as 
follows: ‘Both financial and insurance services’ (106), ‘Mainly financial services’ (42), ‘Mainly insurance services’ 
(6), ‘Other services’ (1), ‘No Answer’ (116).  

8 

 
 
 
                                              
Figure 7.1: Type of customers (Question 18) overall 

Figure 7.2: Type of customers (Question 18) excluding the presumed campaign 

What type of supplies do you make?

56,60%

22,20%

6,60%

14,60%

Both (44)
Mainly business-to-consumers (b2c) (29)

Mainly business-to-business (b2b) (13)
No Answer (112)

9 

 
 
 
Figure 8.1: Markets supplied to (Question 19) overall 

Figure 8.2: Markets supplied to (Question 19) excluding the presumed campaign6 

Which markets do you provide financial and/or insurance
services to?

56,60%

7,10%

18,70%

17,70%

National market and market(s) of other member states (14)
National market only (37)
National market, market(s) of other member states, and market(s) outside the eu (35)
No Answer (112)

6  

The  distribution  of  markets  supplied  to  amongst  respondents  forming  part  of  the  presumed  campaign  is  as 
follows: ‘National market and market(s) of other member states’ (18), ‘National market only’ (137), ‘No Answer’ 
(116). 

10 

 
 
 
                                              
2.2.  Evaluation  of  the  current  VAT  rules  for  financial  and  insurance 

services 

In this part of the questionnaire, the public consultation raised a number of questions 
on the functioning of the current VAT rules for financial and insurance services and the 
respondents’ experience with them.  

Figure 9.1: Need of exemption (Question 20) overall 

Figure 9.2: Need of the exemption (Question 20) excluding the presumed campaign7 

The exemption of financial and insurance services from VAT  
was introduced in 1977 as an exception to the general rule  
that VAT is to be levied on all serviced supplied for  
consideration by a taxable person. To what extent do you  
agree that the exemption is still needed? 

5,60%

1,50%

15,20%

6,10%

8,60%

2,50%

60,60%

Agree (30)
Strongly agree (120)

Disagree (12)
Strongly disagree (11)

Neutral (17)
No answer (3)

Not sure (5)

7   268 of 271 respondents forming part of the presumed campaign indicated ‘Strongly agree’ as their answer. 

11 

 
 
 
                                              
Figure 10.1: Functioning of the exemption (Question 21) overall 

Figure 10.2: Functioning of the exemption (Question 21) excluding the presumed campaign8 

In general, how would you assess the functioning of the
exemption of financial and insurance services? The 
exemption...

5,00% 1,00%

42,90%

34,30%

16,70%

… works poorly and should be improved (68) … works very well (33)
… works well, but could be improved (85)
No answer (2)

… should be removed (10)

8  

267  of  the  271  respondents  forming  part  of  the  presumed  campaign  indicated  ‘Works  well,  but  could  be 
improved’ as their answer. 

12 

 
 
 
                                              
Figure 11: Reasons for why the exemption could/should be improved or removed (Question 22)9 

9  

262 of the 271 respondents forming part of the presumed campaign (i.e. 55.86% of all respondents) indicated 
‘Other’  as  their  answer  and  provided  a  nearly  identical  reply  to  the  follow-up  Question 23  (‘Please  indicate 
which other reason(s)’). 

13 

 
 
                                              
Figure 12: Estimated impact of the lack of input tax deduction and hidden VAT (Question 24)10

10   257 of the 271 respondents forming part of the presumed campaign (i.e. 54.80% of all respondents) indicated 
‘Other’  as  their  answer  and  provided  the  nearly  identical  reply to  the  follow-up  Question 25  (‘Please  indicate 
which other reason(s)). 

14 

 
 
                                              
Figure 13: Compliance with VAT rules in case of cross-border supplies (Question 26)11 

11   237 of the 271 respondents forming part of the presumed campaign rated the factors listed below as follows: 

- 
- 
- 
- 
- 
- 
- 
- 

Difficulty of finding information on VAT obligations in other Member States: Somewhat 
Different interpretations on definitions of exempted services: Somewhat 
Different rules for opting to tax: Not at all 
Availability of VAT grouping: Not at all 
Availability  of cost-sharing arrangements: Not at all 
Different deduction methods: Not at all 
Different VAT obligations in other Member States: Somewhat 
Other: To a large extent. 

15 

 
 
                                              
Figure 14.1: Effect of current rules on cross-border supplies (Question 28) overall 

Figure 14.2: Effect of current rules on cross-border supplies (Question 28) excluding the 
presumed campaign12 

Do you think that the current rules hinder the development
of cross-border supplies of financial and insurance services?

3,50%

7,60%

25,80%

63,10%

Do not know (15)

No (51)

Yes (125)

No Answer (7)

12   268 of the 271 respondents forming part of the presumed campaign indicated ‘No’ as their answer. 

16 

 
 
 
                                              
Figure 15: Reasons for why the current rules hinder the development of cross-border supplies 
(Question 29) 

17 

 
 
Figure 16.1: Correlation between businesses’ decision to establish abroad and applicable VAT 
rules (Question 31) overall 

Figure 16.2: Correlation between businesses’ decision to establish abroad and applicable VAT 
rules (Question 31) excluding the presumed campaign13 

To what extent are the foreign VAT rules for financial and
insurance services important when deciding whether to
establish your business in a specific Member State?

59,60%

10,10%

7,00%

11,10%

10,60%

1,50%

Important (20)

No opinion (14)

Not important at all (22)

Not very important (21)

Very important (3)

No answer (118)

13   148 of the 271 respondents forming part of the presumed campaign indicated ‘Not important at all’ as their 

answer, while 120 of the 271 respondents in question gave no answer. 

18 

 
 
 
                                              
Figure 17: Application of structural provisions by businesses (Question 32)14 

14   152 of the 271 respondents forming part of the presumed campaign (i.e. 32.40% of all respondents) indicated 
‘VAT grouping’ as their answer, while 119 of the 271 respondents in question (i.e. 25.40% of all respondents) 
gave no answer. 

19 

 
 
                                              
Figure 18.1: Tackling the difficulty to calculate the taxable amount (Question 34) overall 

Figure 18.2: Tackling the difficulty to calculate the taxable amount (Question 34) excluding the 
presumed campaign15 

The exemption was put in place i.a. due to the technical 
difficulty to calculate the taxable amount. To what extent do 
you agree that progress in technology, enhanced 
transparency rules and experiences gained from other 
countries and from other indirect taxes could help overcome 
this issue?

13%

2%

8%

7%

24%

28%

18%

Agree (16)
Strongly agree (14)

Disagree (55)
Strongly disagree (25)

Do not know (35)
No Answer (5)

Neutral (48)

15   263 of the 271 respondents forming part of the presumed campaign indicated ‘Disagree’ as their answer 

20 

 
 
 
                                              
Figure 19.1: Impact of VAT rules on prices (Question 35) overall 

Figure 19.2: Impact of VAT rules on prices (Question 35) excluding the presumed campaign16 

Do the current VAT rules for financial and insurance services
result in prices lower than those that would apply if these 
services were taxed?

3,50%

14,10%

50,00%

15,20%

5,60%

11,60%

Do not know (30)
No (23)
Yes, for all customers (28)

In part, due to other similar taxes (11)
Yes, but just for non-taxable customers (99)
No Answer (7)

16   270  of  the  271  respondents  forming  part  of  the  presumed  campaign  indicated  ‘Yes,  but  just  for  final  non-

taxable customers’ as their answer. 

21 

 
 
 
                                              
Figure 20: Effectiveness of structural provisions (Question 36)17 

Figure 21: Complexity of structural provisions (Question 37)18 

17   244  of  the  271  respondents  forming  part  of  the  presumed  campaign  rated  the  structural  provisions’ 

effectiveness as follows: 
- 
- 
- 
- 

Option to tax: No opinion 
VAT grouping: Somewhat effective 
Cost-sharing arrangements: No opinion 
Proportional deduction: No opinion. 

18   270 of the 271 respondents forming part of the presumed campaign (i.e. 57.57% of all respondents) indicated 

‘None’ as their answer. 

22 

 
 
 
                                              
Figure 22.1: Effects of the lack of input tax deduction (Question 38) overall 

Figure 22.2: Effects of the lack of input tax deduction (Question 38) excluding the presumed 
campaign19 

To what extent do you agree or disagree with the following
statement: The lack of input tax deduction is detrimental to
the financial and insurance sector. It compels the sector to
outsource services which are typically provided in-house,
thus raising the costs.

4,50%

10,60%

21,70%

7,80%

15,70%

27,80%

12,10%

Agree (21)
Strongly agree (15)

Disagree (55)
Strongly disagree (43)

Do not know (24)
No Answer (9)

Neutral (31)

19   256 of the 271 respondents forming part of the presumed campaign indicated ‘Disagree’ as their answer. 

23 

 
 
 
                                              
Figure 23.1: Incurred costs related to irrecoverable VAT (Question 39) overall 

Figure 23.2: Incurred costs related to irrecoverable VAT (Question 39) excluding the presumed 
campaign20 

Unless you make use of the option to tax, does your
business incur any costs related to irrecoverable (hidden)
VAT?

8,60%

1,50%

3,00%

60,10%

26,70%

Do not know (17)
No (6)
No Answer (119)

My busines is applying the option to tax (3)
Yes (53)

20   147 of the 271 respondents forming part of the presumed campaign indicated ‘Do not know’ as their answer, 

while 123 of the 271 respondents in question provided no answer. 

24 

 
 
 
                                              
Figure 24.1: Fitness of current rules for emerging trends in the industry (Question 40) overall 

Figure 24.2: Fitness of current rules for emerging trends in the industry (Question 40) excluding 
the presumed campaign21 

To what extent do you agree that the current VAT rules are 
fit to cover emerging trends in the industry (such as
digitalisation)?

2,50%

7,00%

45,50%

24,80%

6,00%

11,60%

2,50%

Agree (14)
Strongly agree (12)

Disagree (90)
Strongly disagree (49)

Do not know (5)
No Answer (5)

Neutral (23)

21   241 of the 271 respondents forming part of the presumed campaign indicated ‘Disagree’ as their answer. 

25 

 
 
 
                                              
Figure 25: Definitions and emerging trends (Question 41)22 

22   248 of the 271 respondents forming part of the presumed campaign (i.e. 52.88% of all respondents) indicated 

‘Services linked to crypto-assets (such as mining)’ as their answer. 

26 

 
 
                                              
Figure 26.1: VAT exemption and the role of intermediaries (Question 43) overall 

Figure 26.2: VAT exemption and the role of intermediaries (Question 43) excluding the 
presumed campaign23 

The regulatory framework in the financial and insurance
sector (e.g. the Markets in Financial Instruments Directive 
(MIFID) and the Insurance Distribution Directive (IDD)) has 
strengthen the role of intermediaries. Do you consider the
VAT exemption to be coherent with this development?

5,10%

20,20%

21,20%

53,50%

Do not know (42)

No (106)

Yes (40)

No Answer (10)

23   265 of the 271 respondents forming part of the presumed campaign indicated ‘No’ as their answer. 

27 

 
 
 
 
                                              
2.3.  Possible  changes  to  the  current  VAT  rules  for  financial  and 

insurance services 

In this final part of the  questionnaire, respondents could give their views on  possible 
changes to the current VAT rules for financial and insurance services.  

Figure 27: Reform of VAT exemption (Question 44)24 

24   263 of the 271 respondents forming part of the presumed campaign (i.e. 56.08% of all respondents) indicated 
‘Other’ as their answer and provided a nearly identical reply to follow-up Question 45 (‘Please indicate which 
other way(s)’). 

28 

 
 
                                              
 
Figure 28: Effects of removal of exemption (Question 46)25 

25   268 of the 271 respondents forming part of the presumed campaign (i.e. 57.14% of all respondents) indicated 
‘Other’ as their answer and provided a nearly identical reply to follow-up Question 47 (‘Please indicate which 
other effect(s)’). 

29 

 
                                              
Figure 29.1: Member States’ discretion in providing option for taxation (Question 49) overall 

Figure 29.2: Member States’ discretion in providing option for taxation (Question 49) excluding 
the presumed campaign26 

Financial service providers may currently opt for taxation
and obtain the right of deduction, but it is up to each
Member State to introduce such option. Should Member
States keep that discretion?

4,00%

8,60%

23,20%

64,10%

No opinion (17)
No, it should be available in all member states (127)
Yes (46)
No Answer (8)

26   269 of the 271 respondents forming part of the presumed campaign indicated ‘Yes’ as their answer. 

30 

 
 
 
                                              
Figure 30.1: Introduction of a fixed rate of input tax deduction (Question 50) overall 

Figure 30.2: Introduction of a fixed rate of input tax deduction (Question 50) excluding the 
presumed campaign27 

Not having a right of deduction when supplying exempt
financial and insurance services impairs the neutrality of
VAT. To what extent would you support or oppose 
the introduction of a fixed rate of input tax deduction to remedy
that effect?

30,30%

3,50%

4,00%

16,20%

23,70%

22,20%

No opinion (32)
Strongly support (7)

Oppose (47)
Support (60)

Strongly oppose (44)
No Answer (8)

27   256  of  the  271  respondents  forming  part  of  the  presumed  campaign  indicated  ‘Strongly  oppose’  as  their 

answer. 

31 

 
 
 
                                              
Figure 31.1: Optional vs. mandatory fixed rate of input tax deduction (Question 51) overall 

Figure 31.2: Optional vs. mandatory fixed rate of input tax deduction (Question 51) excluding 
the presumed campaign28 

If a fixed rate of input tax deduction was introduced, should
such a rule remain optional for operators or, alternatively,
should it be mandatory?

3,50%

7,10%

9,10%

80,30%

It should be mandatory (14)
No opinion (18)

It should be optional (159)
No Answer (7)

28   260 of the 271 respondents forming part of the presumed campaign indicated ‘It should be optional’ as their 

answer. 

32 

 
 
 
                                              
Figure 32.1: Availability of cost-sharing arrangements (Question 52) overall 

Figure 32.2: Availability of cost-sharing arrangements (Question 52) excluding the presumed 
campaign29 

Should cost-sharing arrangements be made available to the 
financial and insurance services sector?

3,00%

4,50%

24,70%

67,70%

No (9)

No opinion (49)

Yes (134)

No Answer (6)

29   266 of the 271 respondents forming part of the presumed campaign indicated ‘No opinion’ as their answer. 

33 

 
 
 
                                              
Figure 33.1: Cross-border cost-sharing arrangements (Question 53) overall 

Figure 33.2: Cross-border cost-sharing arrangements (Question 53) excluding the presumed 
campaign30 

In your view, should businesses established in other Member
States be allowed to form part of the cost sharing
arrangements?

1,00%

5,10%

33,80%

60,10%

No (2)

No opinion (10)

Yes (119)

No Answer (67)

30   268  of  the  271  respondents  forming  part  of  the  presumed  campaign  indicated  gave  no  answer  to  that 

question. 

34 

 
 
 
                                              
Figure 34: Reasons for introduction of cross-border cost-sharing arrangements (Question 54)31 

Figure 35: Reasons against introduction of cross-border cost-sharing arrangements 
(Question 56)32 

31   All  271  respondents  forming  part  of  the  presumed  campaign  (i.e.  57.78%  of  all  respondents)  provided  no 

answer to this question. 

32   All  271  respondents  forming  part  of  the  presumed  campaign  (i.e.  57.78%  of  all  respondents)  provided  no 

answer to this question. 

35 

 
 
                                              
Figure 36: Advantages of VAT grouping (Question 58)33 

33   257 of the 271 respondents forming part of the presumed campaign rated the factors listed below as follows: 

- 
- 
- 

- 
- 
- 

It is optional: Somewhat beneficial 
Intragroup supplies are out of scope and therefore not taxed: Very beneficial 
VAT  compliance  costs  are  lower  for  the  members  of  the  group  as  they  are  pooling  them:  Somewhat 
beneficial 
It is easier to outsource the activity through a single taxable person: Somewhat beneficial 
VAT grouping increases the competitiveness of the sector by reducing hidden VAT: Very beneficial 
Other: No Answer. 

36 

 
                                              
Figure 37: Effective ways to reform the rules (Question 60)34 

34   208 of the 271 respondents forming part of the presumed campaign rated the ways listed below as follows: 

Remove the exemption and tax financial and insurance services at a standard rate: Not effective at all 
Remove the exemption and tax financial and insurance services at a reduced rate: Not effective at all 
Tax only fee-based services at a standard rate: Not effective at all 
Tax only fee-based services at a reduced rate: Not effective at all 
Grant businesses the option to apply VAT: Somewhat effective  
Grant businesses the right to constitute a VAT group in every Member State: Somewhat effective  

- 
- 
- 
- 
- 
- 
-  Make cost-sharing arrangements available to the sector in all Member States: No Answer 
- 

Other: Very effective. 

37 

 
                                              
 
3.  NEXT STEPS 

This  factual  summary  provides  some  key  background  information  and  a  preliminary 
overview of the replies to closed questions.  

In a later “synopsis report”, the Commission will conclude on all consultations  carried 
out  and  feedback  received  during  the  project.  In  particular,  the  synopsis  report  will 
contain  a  detailed  analysis  of  all  contributions  to  the  public  consultation  (including 
responses  to  open  questions  and  position  papers  uploaded  in  addition  to  the 
questionnaire). It will also incorporate the feedback provided at the start of the project 
to the roadmap of the combined evaluation and impact assessment – and a review of 
other  position  papers  submitted  by  stakeholders  to  the  Commission.  Finally,  it  will 
reflect findings from regular meetings with stakeholders and Member States alike. 

The  analysis  of  all  these  consultations  eventually  feeds  into  the  preparation  of  an 
Impact Assessment presenting the overall analysis, findings and options for the review 
of VAT rules for financial and insurance services. The synopsis report will be added as 
specific annex on stakeholder consultations to that Impact Assessment. 

38