REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL pursuant to Article 410b of the VAT Directive, on the application of the VAT rules for vouchers - definition, distribution chains and non-redeemed vouchers -
Date: 2024-07-22
Institutions: Directorate-General for Taxation and Customs Union, European Commission
Subjects: VAT, double taxation, financial instrument, goods and services, tax avoidance, tax collection, tax harmonisation

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 22.7.2024  COM(2024) 307 final  REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL pursuant to Article 410b of the VAT Directive, on the application of the VAT rules for vouchers  - definition, distribution chains and non-redeemed vouchers -  
 
 
Table of contents 

1. 

2. 

3. 

4. 

INTRODUCTION --------------------------------------------------------------------------------------------------------------- 2 

BACKGROUND TO THE INTERVENTION -------------------------------------------------------------------------------- 2 

IMPLEMENTATION OF THE CURRENT PROVISIONS ---------------------------------------------------------------- 8 

ASSESSMENT OF THE CURRENT RULES ------------------------------------------------------------------------------- 12 

4.1 
4.2 

GENERAL ASSESSMENT -------------------------------------------------------------------------------------------------- 12 
ASSESSMENT OF SPECIFIC TOPICS -------------------------------------------------------------------------------------- 16 

5. 

CONCLUSIONS --------------------------------------------------------------------------------------------------------------- 20 

ANNEX - SYNOPSIS REPORT - QUESTIONNAIRE ON THE IMPLEMENTATION OF THE VOUCHER DIRECTIVE 
(EU) 2016/1065 --------------------------------------------------------------------------------------------------------------------- 23 

 
 
1. 

INTRODUCTION  

On  27 June  2016,  the  Council  adopted  a  Directive1  amending  the  VAT  Directive2  on  the 
treatment of transactions involving vouchers (the Voucher Directive). The new rules apply from 
1 January 2019, but only to vouchers issued after 31 December 2018. 

The aim of those changes is the simplification, modernisation and harmonisation of the VAT 
rules  applying  to  vouchers3,in  particular  to  “ensure  certain  and  uniform  treatment,  to  be 
consistent with the principles of a general tax on consumption exactly proportional to the price 
of  goods  and  services,  to  avoid  inconsistencies,  distortion  of  competition,  double  or  non-
taxation and to reduce the risk of tax avoidance”4.  

According to Article 410b of the VAT Directive as amended, the Commission is to present to 
the  European  Parliament  and  to  the  Council  an  assessment  report  based  on  information 
obtained from the EU Member States (Member States from here on) on the application of the 
provisions  of  the  VAT  Directive  as  regards  the  VAT  treatment  of  vouchers,  with  particular 
regard  to  the  definition  of  vouchers,  the  VAT  rules  relating  to  taxation  of  vouchers  in  the 
distribution  chain,  and  to  non-redeemed  vouchers,  accompanied  where  necessary  by  an 
appropriate proposal to amend the relevant rules. 

In light of the above, this report analyses the general performance of the VAT rules on vouchers 
according to five criteria (effectiveness, efficiency, relevance, coherence and EU added value) 
over 4 years since their initial application in 2019, followed by a specific assessment of: i) the 
definition  of  vouchers,  ii)  the  taxation  of  vouchers  in  the  distribution  chain  and  iii)  non-
redeemed vouchers. The report assesses the implementation of the relevant provisions based 
on the results of a survey targeted to Member States carried out from 27 March to 9 June 20235. 
It then concludes by considering whether a legislative proposal to amend the rules concerned 
would be appropriate.  

2. 

BACKGROUND TO THE INTERVENTION  

In the absence of common VAT rules on the treatment of vouchers in the Sixth VAT Directive6 
or in the VAT Directive, Member States have developed different approaches over the years. 
This  has  led  to  risks  of  double  or  non-taxation,  tax  avoidance  and  barriers  to  business 
innovation7. In 2012, the Commission thus put forward a proposal8 to clarify and harmonise 
the VAT rules on vouchers.  

1   Council Directive (EU) 2016/1065 of 27 June 2016 amending Directive 2006/112/EC as regards the treatment 

of vouchers (OJ L 177, 1.7.2016, p. 9) (the Voucher Directive). 

2   Council Directive 2006/112/EC of 28 November 2006 on the common system of value added tax (OJ L 347, 

11.12.2006, p. 1) (the VAT Directive). 

3   Recital 13 of the Voucher Directive. 
4   Recital 2 of the Voucher Directive. 
5   Questionnaire on the implementation of the Vouchers Directive (EU) 2016/1065. 
6   Council  Directive  77/388/EEC  of  17 May  1977  on  the  harmonization  of  the  laws  of  the  Member  States 
relating  to  turnover  taxes  –  Common  system  of  value  added  tax:  uniform basis  of  assessment  (OJ L 145, 
13.6.1977, p. 1) (the Sixth VAT Directive). 

7   From  the  114th meeting  of  the  VAT  Committee,  Working  paper  No 983,  Questions  raised  following 

implementation of the Voucher Directive. 

8   Proposal for a Council Directive amending Directive 2006/112/EC on the common system of value added 

tax, as regards the treatment of vouchers (COM(2012) 206 of 10.5.2012). 

2 

 
 
 
When  adopted  by  the  Council,  some  of  the  provisions  the  Commission  had  proposed  were 
however left out. In particular, the adopted Voucher Directive does not contain any provision 
on discount vouchers, payments on account or the calculation of the taxable amount for the 
distribution  of  ‘multi-purpose  vouchers’  (MPVs).  On  discounts,  the  recitals  of  the  adopted 
Directive  even  clarify  that  instruments  entitling  the  holder  to  a  discount  upon  purchase  of 
goods or services but carrying no right to receive such goods or services should not be targeted 
by these rules. Nor is any reference made to the exclusion from the definition of a voucher of 
any instrument whose sole purpose is the making of payments, nor to the relationship between 
the rules on vouchers and special VAT rules, such as those on the margin scheme for travel 
agents. It could be argued that this is partially due to unanimity being required in the field of 
taxation, where the compromises reached often leave aside issues that potentially could have 
been  agreed  on  by  majority.  Indeed,  over  the  past  few  years,  these  and  other  issues  of 
implementation have been discussed in the context of the VAT Committee9, resulting in two 
sets  of  guidelines10  agreed  by  a  majority  of  Member  States  (Section 3)  which,  although  not 
legally binding, do contribute to a more uniform application of the common VAT rules.  

i) The definition of vouchers 

The rules as adopted provide that for an instrument to qualify as a voucher two cumulative 
conditions must be met: i) the instrument entails an obligation to accept it as consideration or 
part of the  consideration for a supply of goods or services  and ii) the instrument  or  related 
documentation specifies the goods or services to be supplied or the identity of the potential 
suppliers.  

9   Pursuant to Article 398 of the VAT Directive “1. An advisory committee on value added tax, called "the VAT 
Committee", is set up. 2. The VAT Committee shall consist of representatives of the Member States and of the 
Commission.  The  chairman  of  the  Committee  shall  be  a  representative  of  the  Commission.  Secretarial 
services for the Committee shall be provided by the Commission. 3. The VAT Committee shall adopt its own 
rules of procedure. 4. In addition to the points forming the subject of consultation pursuant to this Directive, 
the VAT Committee shall examine questions raised by its chairman, on his own initiative or at the request of 
the representative of a Member State, which concern the application of Community provisions on VAT.” 
10   Guidelines agreed at the 116th meeting, Working paper No 1043, Document B, taxud.c.1(2023)4439781 and 
Guidelines agreed at the 122nd meeting, Working paper No 1074, Document C, taxud.c.1(2024)438498. 

3 

 
 
 
 
 
Figure 1: Concept of voucher11 

A  ‘single-purpose  voucher’  (SPV)  is  a  voucher  where  the  place  of  supply  of  the  goods  or 
services to which the voucher relates, and the VAT due on those goods or services, are known 
at the time of issue of the voucher, while all vouchers other than SPVs constitute ‘multi-purpose 
vouchers’ (MPVs).  

Figure 2: SPV 

11   Figures 1  to  5  are  from  the  VAT  Committee  Working  Paper  No 983  ‘Questions  raised  following 

implementation of the Voucher Directive’. 

4 

Single-purpose voucheris a voucher* where ...The place of supply of the goods or services to which the voucher relatesThe VAT due on those goods or servicesAre known at the time of issueof the voucherand* meeting the conditions of the definition givenVoucheris an instrument where there is ...Obligation to accept as (part) consideration for supply ofgoods or servicesGoods or services to be supplied are knownIdentities of potential suppliersare indicated or appear from related documentationandor 
 
 
 
 
 
 
Figure 3: Concept of an MPV 

The  recitals  of  the Voucher  Directive  also  clarify  that  instruments  entitling  the  holder  to  a 
discount upon purchase of goods or services but carrying no right to receive such goods or 
services  should  not  be  targeted  by  these  rules12  and  that  the  provisions  regarding  vouchers 
should not trigger any change in the VAT treatment of transport tickets, admission tickets to 
cinemas and museums, postage stamps or similar13. 

ii) VAT treatment of vouchers in the distribution chain  

As Recital 8 of the Voucher Directive states, where the VAT treatment of the underlying supply 
of  goods  or  services  can  be  determined  with  certainty  already  upon  issue,  VAT  should  be 
charged on each transfer of an SPV, including on its issue, while the actual handing over of the 
goods or the actual provision of the services in return for a SPV should not be regarded as an 
independent transaction.  

12   Recital 4 of the Voucher Directive. 
13   Recital 5 of the Voucher Directive. 

5 

Multi-purpose voucheris a voucher* other than ...A single-purpose voucher* meeting conditions of the definition given 
 
 
 
 
 
 
 
Figure 4: Rules governing the transfer of an SPV 

On the distribution of SPVs, the Voucher Directive clarified that each transfer of an SPV by a 
taxable person who acts in his own name, including the issue of that voucher, is regarded as 
being  the  supply  of  the  goods  or  services  to  which  the  voucher  relates14.  VAT  should  be 
accounted  on  the  consideration  received  for  the  SPV  according  to  Article 73  of  the  VAT 
Directive. If, on the other hand, an SPV is issued or distributed by a taxable person acting in 
the name of another person, that taxable person would not be regarded as taking part in the 
underlying supply. 

For MPVs, VAT should instead be charged when the goods or services to which the voucher 
relates are supplied, therefore, any prior transfer of the MPV should not be subject to VAT. 

14   Recital 9 of the Voucher Directive. 

6 

Enterprise 1Enterprise 2Final consumerActing in own name or in that of another taxable person?TransferTransferRedemptionRedeemerDeemed supply in case redeemer   enterprise 1 No independent transactionVATVATVAT 
 
 
 
 
 
 
Figure 5: Rules governing the transfer of an MPV 

On services provided along the distribution chain of an MPV, only the intermediary services or 
separate supply of services such as distribution or promotion services would be subject to VAT. 
Therefore, where a taxable person who is not acting in his own name receives any separate 
consideration upon the transfer of an MPV, that consideration should be taxable according to 
the normal VAT arrangements15. 

Finally, on the taxable amount of an MPV, the Voucher Directive clarified that to ensure that 
the amount of VAT paid is accurate, without prejudice to Article 73 of the VAT Directive, the 
supplier of the goods or services should account for the VAT based on the consideration paid 
for the MPV16. In the absence of such information the taxable amount should be equal to the 
monetary value indicated on the voucher itself or in the related documentation, less the amount 
of VAT relating to the goods or services supplied. Where an MPV is used partially in respect 
of the supply of goods or services, the taxable amount should be equal to the corresponding 
part of the consideration or the monetary value, less the amount of VAT relating to the goods 
or services supplied. 

iii) Non-redeemed vouchers 

Where an MPV is partially used, the taxable amount should be equal to the corresponding part 
of the consideration or the monetary value, minus the amount of VAT relating to the goods or 
services supplied, although it is clarified17 that this does not target the situations where a multi-

15   Recital 10 of the Voucher Directive. 
16   Recital 11 of the Voucher Directive. 
17   Recital 11 of the Voucher Directive. 

7 

Enterprise 1Enterprise 2Final consumerTransferTransferRedemptionRedeemer(supplier of goodsor services)Taxable amount equal to consideration paid or, absent information, monetary value on voucherDistribution orpromotion service?VATVATVAT 
 
 
 
 
 
 
purpose  voucher  is  not  redeemed  by  the  final  consumer  during  its  validity  period,  and  the 
consideration received for such voucher is kept by the seller18. 

3. 

IMPLEMENTATION OF THE CURRENT PROVISIONS 

According to Article 2 of the Voucher Directive: 

1.  Member  States  shall  adopt  and  publish,  by  31 December  2018  at  the  latest,  the  laws, 
regulations and administrative provisions necessary to comply with this Directive. They shall 
forthwith communicate to the Commission the text of those provisions. They shall apply those 
provisions from 1 January 2019.  

2.  Member  States  shall  communicate  to  the  Commission  the  text  of  the  main  provisions  of 
national law which they adopt in the field covered by this Directive. 

With regard to the obligation to communicate to the Commission the text of the new provisions, 
five non-communication infringement procedures were closed after Cyprus, Czechia, Greece, 
Latvia and Romania communicated their transposition measures. 

The compliance check of each Member State conducted by DG TAXUD19 after 1 January 2019 
showed that four Member States had failed to adhere to the prescribed dates of entry into force 
and  application  of  the  new  provisions  (in  Czechia  the  amendments  entered  into  force  from 
1 April 2019, in Denmark and Latvia the new provisions only applied to vouchers issued after 
1 July 2019 and in Slovakia to vouchers issued after 30 September 2019). 

In  addition,  following  the  compliance  checks,  the  Commission  opened  two  EU  Pilot 
procedures20  towards  Bulgaria  and  France.  In  the  case  of  Bulgaria,  the  EU  Pilot  procedure 
relating to the treatment of meal vouchers was closed after the national legislation was modified 
as of 18 February 2022. In particular, as a result of the amendments made, meal vouchers that 
could be exchanged both for supplies subject to a reduced VAT rate and for supplies taxed at 
the standard rate, were regarded as MPVs. In the case of France, the EU Pilot procedure related 
to  the  determination  of  the  taxable  amount  of  the  supply  of  goods  or  services  provided  in 
respect  of  an  MPV  in  the  absence  of  information  on  the  consideration  paid. According  to 
Article 73a of the VAT Directive, indeed, in this case the taxable amount shall be equal to the 
monetary value indicated on the voucher itself or in the related documentation, less the amount 
of VAT relating to the goods or services supplied. After the national legislation was modified 
accordingly, entering into force as of 1 January 2022, the file was closed.  

As regards the EU case law,  for the first  time21 the Court of Justice of the European Union 
(CJEU)  dealt  with  the Voucher  Directive  in  the  DSAB  Destination  Stockholm  case22,  which 
concerned the interpretation of Article 30a of the VAT Directive in relation to a ‘city card’. The 
question referred sought to determine whether an instrument which gives the bearer the right 

18   Recital 12 of the Voucher Directive. 
19   The compliance check only covers transposition measures and not issues of concrete application of the law. 
20   EU Pilot is a mechanism for informal dialogue between the Commission and the Member State concerned on 
issues  relating  to  potential  non-compliance  with  EU  law.  It  can  be  used  before  launching  a  formal 
infringement procedure. 

21   The CJEU also referred to vouchers in its judgment of 17 November 2022, C-607/20, GE Aircraft Engine 

Services, EU:C:2022:884, although that dealt with the rules in force before the Voucher Directive. 

22   CJEU, judgment of 28 April 2022, DSAB Destination Stockholm, EU:C:2022:304. 

8 

 
 
 
to use various services at a given place, for a limited period and up to a certain amount, can 
constitute a ‘voucher’ within the meaning of Article 30a(1) of the VAT Directive even if, on 
account of the limited validity period of that instrument, an average consumer cannot benefit 
from all the services offered, and whether, if it can, such an instrument can constitute an MPV 
within the meaning of Article 30a(3) of the VAT Directive.  

First,  the  CJEU  found  that  the  conditions  for  being  qualified  as  a  voucher  according  to 
Article 30a seemed to  be satisfied (provided it is also  ascertained by the referring  court). It 
clarified that the two conditions are cumulative: i) the instrument must entail an obligation to 
accept it as consideration or part consideration for a supply of goods or services, and ii) the 
instrument or related documentation must specify the goods or services to be supplied or the 
identity  of  the  potential  suppliers  thereof.  On  the  contrary,  the  validity  period  of  the  card 
concerned  or  the  ability  to  take  advantage  of  all  the  services  covered  by  that  card  are  not 
relevant elements for the purposes of classifying that card as a ‘voucher’ within the meaning 
of Article 30a. Second, it was recalled that the card at issue allows access to various supplies 
of services, which are subject to different rates of VAT or are tax exempt and that it is impossible 
to predict in advance which services will be selected by the cardholder. Since the VAT due on 
those services is not known at the time of issuance of that instrument, it cannot be qualified as 
an SPV. The CJEU therefore found that the instrument constitutes an MPV within the meaning 
of Article 30a(3) of the VAT Directive, as this concept is residual in scope (all vouchers other 
than SPVs constitute MPVs). 

More recently, the judgement by the CJEU in the Finanzamt O (Bons à usage unique) case23 
focused on whether  a chain  of distribution between economic operators  acting in  their own 
name across the EU before the services to which the voucher relates are supplied to the final 
consumers may affect the condition for an SPV to exist, i.e. that “the place of supply of the 
goods or services to which the voucher relates, and the VAT due on those goods or services, 
are known at  the time of issue of  the voucher”. The CJEU ruled that the classification of a 
voucher as an SPV within the meaning of Article 30a(2) of the VAT Directive depends solely 
on the conditions laid down in that provision, which include the requirement that the place of 
supply of services to end consumers, to which that voucher relates, must be known at the time 
of the issue of that voucher, irrespective of the fact that the voucher is the subject of transfers 
between taxable persons acting in their own name and established in the territory of Member 
States other than that in which those end consumers are located. In essence, the CJEU found 
that  the  successive  transfers  of  an  SPV  made  by  taxable  persons  acting  in  their  own  name, 
which  are  to  be  regarded  as  the  supply  to  which  the  voucher  relates  pursuant  to  the  first 
subparagraph of Article 30b(1), do not call into question the assessment made at the time of 
issue  of  the  voucher  on  whether  that  voucher  classifies  as  SPV,  and  more  specifically,  on 
whether the place of supply of the services to which the voucher relates is known at the time 
of  issue.  Indeed,  the  CJEU  noted  that  the  first  subparagraph  of Article 30b(1)  of  the  VAT 
Directive  only  applies  to  vouchers  (already)  being  qualified  as  SPV  according  to  the  two 
cumulative criteria set out in Article 30a(2) which must be assessed at the time of issue of the 
voucher. The CJEU noted that a different interpretation would otherwise make the qualification 
of a voucher (as SPV or MPV) dependent on whether it is transferred within a single Member 
State  or  within  a  cross-border  distribution  chain.  This  would  run  counter  to  the  original 
objectives  of  the  VAT  provisions  on  vouchers  which  aimed  at  preventing  inconsistencies, 

23   CJEU jugement of 18 April 2024, Finanzamt O (Bons à usage unique), C-68/23, EU:C:2024:342. 

9 

 
 
 
double or non-taxation and mismatches across Member States. It would also make it virtually 
impossible to classify any voucher as a SPV. 

Issues  of  legal  interpretation  and  implementation  have  also  been  discussed  by  the  VAT 
Committee on several occasions24 with a view to contributing to a more uniform application of 
the provisions of the VAT Directive, as amended by the Voucher Directive.  

In particular, the VAT Committee analysed the VAT rules on vouchers in relation to city cards, 
payment instruments and utility tokens, as well as their relationship with VAT special schemes 
and exemptions (i.e. medical exemptions), including the specific exemptions laid down for the 
exportation of goods.  

As support was shown by a majority of Member States, the VAT Committee also agreed on two 
sets of guidelines25 on the VAT treatment of vouchers which, although not legally binding for 
Member States, do contribute to a more uniform application of the common VAT rules26. 

With the first set of guidelines27, the following was agreed: 

1.  Because  a  voucher  is  an  instrument  where  there  is  an  obligation  to  accept  it  as 
consideration or part consideration for a supply of goods or services with the potential 
supplier(s) specified at the time of issuance, the VAT Committee unanimously recognises 
that it must be seen as a limited-purpose instrument.  

2. 

3. 

The VAT Committee is of the almost unanimous view that a voucher cannot be considered 
a payment instrument, given that it is an instrument that constitutes the consideration in 
exchange  for  supplies  of  goods  or  services  embedded  therein  and  not  an  instrument 
having  the  effect  of  transferring  funds.  The  VAT  Committee  therefore  almost 
unanimously agrees that the redemption of a voucher shall not be seen as a payment but 
rather, as the exercise, of a right to obtain the goods or services to which the voucher 
relates. In this regard, the VAT Committee notes, by almost unanimity, that the holder of 
a voucher is entitled to benefit from the goods or services upon redemption of the voucher 
which the supplier is obliged to accept as consideration. 

The VAT Committee confirms by unanimity that a voucher only qualifies as such, if the 
goods or services to be supplied or the identities of their potential suppliers are indicated 
either  on  the  instrument  itself  or  in  related  documentation,  including  its  terms  and 
conditions. With regard to tokens, which are not yet part of a regulated market within the 
EU and whose nature is subject to change, the VAT Committee is of the unanimous view 

24   At  the  112th  (Information  Paper  on  the  VAT  treatment  of  “city  cards”  taxud.c.1(2019)2690215),  114th 
(Working  paper  No 983,  Questions  raised 
the  Voucher  Directive, 
following 
taxud.c.1(2019)7743273), 116th (Working paper No 993, Questions raised following implementation of the 
Voucher  Directive  -  further  analysis  (taxud.c.1(2020)1245810),  117th  (Working  paper No 1001,  Vouchers 
and the Retail Export Scheme and exports of goods, taxud.c.1(2020)6420470), and 122nd meetings (Working 
paper No 1062, Vouchers in the form of City Cards – follow-up, taxud.c.1(2023)1892223). 

implementation  of 

25   Guidelines agreed at the 116th meeting, Working paper No 1043, Document B, taxud.c.1(2023)4439781 and 
Guidelines agreed at the 122nd meeting, Working paper No 1074, Document C, taxud.c.1(2024)438498. 

26   Article 398 of the VAT Directive. 
27   Guidelines agreed at the 116th meeting, Working paper No 1043, Document B, taxud.c.1(2023)4439781. 

10 

 
 
 
that, in principle, they shall not be considered vouchers within the meaning of the VAT 
Directive.  The  VAT  Committee  nevertheless  unanimously  agrees  that  a  case-by-case 
approach  is  appropriate  when  considering  whether  a  token  qualifies  as  a  voucher, 
depending on its specific qualification and use. 

4. 

The  VAT  Committee  almost  unanimously  agrees  that  the  provisions  of  VAT  special 
schemes,  such  as  those  applicable  to  small  enterprises,  travel  agents  or  second-hand 
goods, works of art, collectors’ items and antiques, being exceptions to the general VAT 
rules,  shall  prevail  over  the  application  of  the  rules  applying  to  vouchers  and  other 
general rules, where any of those rules would conflict with the correct application and 
objectives of the special scheme. The VAT Committee almost unanimously agrees that 
the  nature  of  a  voucher  shall  not  be  altered  by  the  fact  that  the  person  issuing  or 
transferring the voucher meets the conditions to apply a special scheme.  

With the second set of guidelines28, the following was agreed: 

1.  In light of the ruling of the Court of Justice of the European Union in case C-637/20 DSAB 
Destination Stockholm, the VAT Committee unanimously confirms that to be classified as 
a voucher pursuant to Article 30a, point (1), of the VAT Directive an instrument such as a 
city card (i) must entail an obligation to accept it as consideration or part consideration for 
a supply of goods or services, and (ii) the goods or services to be supplied or the identity 
of the potential suppliers thereof must be specified in the city card or related documents, 
including the terms and conditions of use. The VAT Committee also by unanimity confirms 
that  these  conditions  are  cumulative  and  must  both  be  met  for  any  instrument  to  be 
classified as a voucher. 

2.  Given that the classification of an instrument depends on factual circumstances, the VAT 
Committee unanimously acknowledges that not all city cards will necessarily qualify as a 
voucher. The VAT Committee however agrees almost unanimously that a city card giving 
the cardholder a right to use the card as consideration for admission to selected attractions 
to be supplied by designated third-party suppliers and for access to use tour buses and boats 
granted by the issuer of the city card at a given place for a limited period and up to a set 
amount, shall qualify as a voucher pursuant to Article 30a, point (1), of the VAT Directive. 

3.  The VAT Committee agrees almost unanimously that where services supplied by way of a 
city card are subject to different rates of VAT or in part tax exempt so that the VAT due on 
the services is not known at the time the city card is issued, the card must be classified as a 
multi-purpose voucher in accordance with Article 30a, point (3), of the VAT Directive. If 
so, the VAT Committee agrees almost unanimously that the taxable amount of the supply 
of services provided in that respect shall be equal to the consideration paid for the city card 
or, in the absence of information on that consideration, the monetary value indicated on the 
city  card  itself  or  in  the  related  documentation,  less  the  amount  of  VAT  relating  to  the 
services supplied. 

28   Guidelines agreed at the 122nd meeting, Working paper No 1074, Document C, taxud.c.1(2024)438498. 

11 

 
 
 
4.  Where, as is the case under the business model examined, services are supplied both by the 
issuer  of  a  city  card  and  by  third-party  suppliers,  the  VAT  Committee  agrees  almost 
unanimously that the taxable amount of the service supplied by the issuer of the city card 
consisting in the running of tour buses and boats for use by the cardholder shall be equal to 
the consideration paid for that city card less the amount of VAT, reduced by any amounts 
paid  to  third-party  suppliers  for  services  supplied  by  them  by  virtue  of  the  city  card  in 
question. 

5.  Under the business model examined where services are supplied both by the issuer of a city 
card and by third-party suppliers, the VAT Committee agrees almost unanimously that in 
respect of services such as admission to museums and attractions or sightseeing provided 
by  a  third-party  supplier  to  the  cardholder  for  which  the  city  card  is  used  as  part 
consideration, the taxable amount shall be the monetary value of the service supplied as 
indicated  in  the  related  documentation,  less  the  amount  of VAT  relating  to  that  service. 
Where  the  agreement  between  the  issuer  of  the  city  card  and  the  third-party  supplier 
stipulates that the monetary value of the service amounts to a percentage of its normal price, 
the VAT Committee agrees almost unanimously that this reduction shall be regarded as a 
price discount obtained at the time of the supply. 

4. 

ASSESSMENT OF THE CURRENT RULES 

The following assessment is based on information obtained from the Member States through a 
survey ran from 27 March to 9 June 2023 to which all Member States replied.  

The survey contained 45 closed and 22 open questions concerning: i) a general assessment of 
the impacts of the implementation of the Voucher Directive over 4 years since its adoption, and 
ii) specific issues related to the definition of vouchers, the distinction between SPVs and MPVs, 
their transfer, taxable amounts, discount vouchers and non-redeemed vouchers (for a detailed 
report of the survey results see Annex - synopsis report). 

The general assessment showed that the majority of Member States did not have enough 
information to reply to most of the questions but, insofar as information was available, the 
VAT rules on vouchers are perceived as having broadly achieved their objectives and as 
mostly relevant. As regards the second part of the assessment, general positive feedback was 
received  regarding  the  provisions  regulating  the  definition  of  vouchers  and  their  transfer 
while  only  a  minority  of  Member  States  raised  specific  issues  that,  however,  mainly 
pertained  to  the  application  of  the  rules  as  they  stand  and  that  were  already  the  subject  of 
discussions in the VAT Committee or of judgments of the CJEU. 

4.1  General assessment 

Effectiveness 

The analysis has shown that the VAT rules on vouchers mostly achieve their objectives. 

As  mentioned  in  Section 1,  the  aim  of  the  Voucher  Directive  was  the  simplification, 
modernisation and harmonisation of the VAT rules applying to vouchers29, and in particular to 
‘ensure certain and uniform treatment, to be consistent with the principles of a general tax on 

29   Recital 13 of the Voucher Directive. 

12 

 
 
 
consumption exactly proportional to the price of goods and services, to avoid inconsistencies, 
distortion of competition, double or non-taxation and to reduce the risk of tax avoidance’30.  

Based on replies to the survey31, a majority of Member States agreed that the implementation 
of the Voucher Directive over the first 4 years has led, at least in part, to i) simpler compliance, 
and ii) more uniform requirements.  

Further  to  this,  the  compliance  check  performed  by  DG  TAXUD,  as  shown  in  Section 3, 
although limited to formal aspects of the legislation, did not find any major problems with the 
transposition of the rules on vouchers by Member States.  

The work done over the last few years in the context of the VAT Committee leading to two sets 
of  guidelines  being  agreed32,  has  further  contributed  to  achieving  the  objective  of 
harmonisation.  

On  whether  the VAT  rules  on  vouchers  have  addressed  issues  relating  to  fraud,  the  great 
majority of Member States did not have enough information. In reply to the survey’s open 
questions, only a minority of Member States drew attention to potential issues of abuse . 
According to one Member State, vouchers could be used for money laundering and there is a 
risk of abuse in the possibility for taxable persons to configure a voucher as an SPV or an MPV. 
This risk of abuse, due to the thin dividing line between SPVs and MPVs, was also pointed out 
by another Member State according to which introducing a legal presumption that goods are 
deemed  to  have  been  supplied  or  services  provided  when  an  SPV  is  issued  also  creates  an 
opportunity  for fraudsters. According to  another  Member State, taxable persons can change 
their business model after issuing a voucher in order for it to be qualified  as an MPV. Two 
other Member States confirmed that issuers tend to extend the range of redeemable goods and 
services subject to different tax rates in order for a voucher to be qualified as an MPV rather 
than an SPV.  

Efficiency 

The analysis has shown that Member States do not have enough information to establish 
whether or not the VAT rules on vouchers have resulted in efficiency gains or losses. 

From  the  survey,  indeed,  the  vast  majority  of/  almost  all  Member  States  did  not  have 
enough information on whether, over the first 4 years, the VAT rules on vouchers resulted in 
the reduction of administrative costs for companies issuing and/or transferring SPVs or MPVs 
and for tax/customs administrations. 

The  replies  to  the  survey’s  open  questions  show  that  most  of  the  problems  raised  with  the 
administration of the new rules, for both tax administrations and taxable persons, related to the 
qualification of certain instruments (e.g. city cards or tokens), and the distinction between SPVs 
and MPVs. Other issues pertained to the determination of the taxable amount of MPVs and to 
their transfer (e.g. distribution services and redeemed MPVs). These were, however, raised by 

30  Recital 2 of the Voucher Directive. 
31   See Annex for the synopsis report of the replies to the survey. 
32   Guidelines agreed at the 116th meeting, Working paper No 1043, Document B, taxud.c.1(2023)4439781 and 
guidelines agreed at the 122nd meeting, Working paper No 1074, Document C, taxud.c.1(2024)438498. 

13 

 
 
 
a minority  of Member States and pertained to  subjects  already being  discussed by the VAT 
Committee, all referring to aspects of application of the current rules. 

Relevance 

Insofar as information is available to Member States, the analysis has shown that the current 
rules are considered mostly relevant. 

In the survey, indeed, the majority of Member States agreed that the implementation of the 
Voucher Directive over the first 4 years had led, at least in part, to VAT rules on vouchers that 
were adapted to various business models. 

Almost half of Member States also agreed that the implementation of the Voucher Directive 
had led, at least in part, to VAT rules that were fit to deal with new and upcoming business 
models. The other half (except one33) of Member States did not have enough information 
to be able to express their view on this. 

Almost half34 of Member States agreed that the implementation of the Voucher Directive had 
led, at least in part, to VAT rules that were fit to deal with cross-border situations. On this, 
half of Member States did not have enough information. 

In  this  regard,  in  reply  to  the  survey’s  open  questions,  only  a  minority  of  Member  States 
mentioned the distinction between vouchers and other new instruments (such as tokens, game 
keys) and the cross-border trade of vouchers as a possible source of problems. While on the 
distinction between different instruments, as mentioned above, there are ongoing discussions 
in  the VAT Committee, on the cross-border trade of vouchers  a  recent judgement  has  been 
issued by the CJEU35. 

Coherence 

The analysis has shown that the VAT rules on vouchers are in line with the principles of the 
VAT system. 

As mentioned before, one of the objectives of the Voucher Directive was to ensure consistency 
with the principles of a general tax on consumption exactly proportional to the price of goods 
and services.  

This is ensured for SPVs by the rule36 under which each transfer of an SPV must be regarded 
as a supply of the underlying goods or services, while the actual supply of goods or services in 
return  for  the  SPV  is  not  seen  as  an  independent  transaction.  This  rule  applies  as  for  these 
vouchers the place of supply and the VAT due in respect of the underlying goods or services 
are known at the time of issue. This is also coherent with the legal fiction in Article 28 of the 
VAT Directive, according to which a taxable person, who takes part in a supply of services, 
must be seen as having received and supplied the services in question when acting in their own 
name but on behalf of another person. Pursuant to Article 73 of the VAT Directive, the taxable 

33   The Member State in question replied ‘not at all’. 
34   Two Member States replied ‘not at all’. 
35   CJEU jugement of 18 April 2024, Finanzamt O (Bons à usage unique), C-68/23, EU:C:2024:342. 
36   Article 30b(1) of the VAT Directive 

14 

 
 
 
amount  of  an  SPV  is  the  full  price  obtained  in  exchange  for  that  SPV  (including  any 
intermediation service). 

Consistency with the VAT system is also ensured by the rule37 applying to MPVs, according 
to which VAT on the underlying goods and services is charged only at the time of redemption. 
This applies because for MPVs it is necessary to wait until the goods or services are actually 
supplied in order to know the VAT due. This ensures that the tax treatment of the transaction is 
the same regardless of whether the goods or services are supplied through the use of a voucher. 
The calculation of the taxable amount under the special rule in Article 73a of the VAT Directive 
also ensures consistency with the VAT principle under which the taxable amount for the VAT 
to be collected by the tax authorities cannot exceed the consideration actually paid by the final 
consumer38. For this reason, the taxable amount is equal to the consideration paid, when known, 
or otherwise to the monetary value indicated on the MPV or in related documentation, minus 
the VAT on the goods or services supplied. 

Where the transfer of an MPV is made by a taxable person other than the actual supplier of 
the  goods  or  services,  VAT  has  to  be  charged  on  any  supply  of  distribution  or  promotion 
services along the chain. This is also in line with the VAT system, ensuring that the totality of 
taxable operations associated with an MPV – its distribution and the supply of the underlying 
goods or services– is taxed in a comprehensive, neutral and transparent manner. The taxable 
amount of these services has to be determined according to Article 73 of the VAT Directive. 

Consistency with the VAT system is also ensured when, as agreed by the VAT Committee, i) 
the provisions of VAT special schemes, such as those applicable to small enterprises, travel 
agents or second-hand goods, works of art, collectors’ items and antiques, being exceptions to 
the general VAT rules, are to prevail over the application of the rules on vouchers and other 
general  rules,  where  any  of  those  rules  would  conflict  with  the  correct  application  and 
objectives of the special scheme and ii) the nature of a voucher is not to be altered by the fact 
that  the  person  issuing  or  transferring  the  voucher  meets  the  conditions  to  apply  a  special 
scheme. 

As regards the interaction of the VAT rules on vouchers with other policy initiatives, the initial 
Commission  proposal  on  the  VAT  treatment  of  vouchers  clarified  that a  payment  service 
within the meaning of Directive 2007/64/EC39 shall not be regarded as a voucher. Although 
this provision was left out when the rules were adopted in the Council, after two papers40 VAT 
Committee guidelines were agreed on that for VAT purposes “a voucher cannot be considered 
a  payment  instrument  given  that  it  is  an  instrument  that  constitutes  the  consideration  in 
exchange for supplies of goods or services embedded therein and not an instrument having 
the effect of transferring funds”. The holder of a voucher is indeed entitled to benefit from the 
goods or services upon redemption of the voucher which the supplier is obliged to accept as 
consideration. These conclusions were reached by the VAT Committee also on the basis of the 

37   Article 30b(2) of the VAT Directive 
38   CJEU, judgment of 24 October 1996 in case C-317/94, Elida Gibbs, EU:C:1996:400, paragraph 19. 
39   Subsequently repealed and replaced by Directive 2015/2366 (Payment Service Directive – PSD2). 
40   114th VAT Committee meeting, Working paper No 983, Questions raised following implementation of the 
Voucher  Directive  (taxud.c.1(2019)7743273),  116th VAT  Committee  meeting,  Working  paper  No 993, 
Questions 
further  analysis 
(taxud.c.1(2020)1245810). 

the  Voucher  Directive 

implementation  of 

following 

raised 

- 

15 

 
 
 
definition  under  the  Payment  Service  Directive  (PSD2)41  of  “payment  instrument”  which 
means a personalised device(s) and/or set of procedures agreed between the payment service 
user and the payment service provider and used in order to initiate a payment order. 

EU added value 

As previously mentioned, the Voucher Directive aims to clarify and harmonise the rules on the 
VAT  treatment  of  vouchers  in  the  absence  of  which  Member  States  had  developed 
uncoordinated solutions, leading to risks of double or non-taxation, tax avoidance and barriers 
to business innovation. 

The problems addressed by the Voucher Directive have a Single Market dimension since the 
lack of uniform VAT treatment of vouchers throughout the EU could result in distortions which 
the common EU VAT system should prevent by ensuring the proper functioning of the market. 
These  problems  could  not  have  been  addressed  by  Member  States  alone.  Against  this 
background, EU added value has been ensured by the current rules.  

However, in the replies to the survey, no clear views were expressed in this regard. Almost 
half42 of Member States agreed that the VAT rules on vouchers have provided benefits to the 
tax/customs administration, at least in part, although almost half of Member States did not 
have enough information on this.  

The  majority  of  Member  States  did  not  have  enough  information  on  whether  the  VAT 
rules on vouchers provided benefits to the sector. Likewise, the vast majority/almost all of 
Member  States  did  not  have  enough  information  on  whether  these  rules  had  resulted  in  an 
increase in domestic or cross-border trade of vouchers. 

4.2 

Assessment of specific topics 

Other than the general assessment on the application of the provisions of the VAT Directive as 
regards the VAT treatment of vouchers, a specific assessment was carried out especially on the 
definition of vouchers, the VAT rules relating to taxation of vouchers in the distribution chain 
and on non-redeemed vouchers.  

As resulted from the survey, general positive feedback was received regarding the provisions 
regulating the definition of vouchers and their transfer. 

The  majority  of  Member  States  agreed/strongly  agreed  that  the  provisions  on  the  general 
definition of a voucher, on the definition of SPVs and their distinction from MPVs and on the 
transfer  of  SPVs  and  MPVs  i)  are  clear  and  easy  to  apply  and  allow  for  the  national 
administration to provide clear guidance to taxable persons in individual situations and ii) are 

41   Directive (EU) 2015/2366 of the European Parliament and of the Council of 25 November 2015 on payment 
services  in  the  internal  market,  amending  Directives  2002/65/EC,  2009/110/EC  and  2013/36/EU  and 
Regulation (EU) No 1093/2010, and repealing Directive 2007/64/EC (OJ L 337, 23.12.2015, p. 35). 

42   Three Member States replied “not at all”. 

16 

 
 
 
clear for taxable persons in order for them to comply with their obligations43. The majority of 
Member States also agreed that these provisions enabled the national administration to enforce 
the applicable rules.  

With  regard  to  the  distribution  of  MPVs,  for  which  there  is  no  specific  provision  in  the 
Voucher Directive, the majority of Member States agreed that the distribution by a taxable 
person, other than the issuer of the voucher, is a supply of services for the purposes of the VAT 
Directive and that the taxable amount of such a distribution service is equal to the difference 
between the nominal value of the voucher and the purchase price paid, less the amount of VAT 
related to the distribution service supplied. With regard to ‘discount vouchers’, on which the 
Voucher  Directive  does  not  include  any  specific  rule  either,  half/the  majority  of  Member 
States did not have enough information to express a view on whether their distribution by a 
taxable person, other than the issuer of the voucher, is the supply of a redemption service if the 
taxable  person  supplying  the  goods  or  services  to  which  the  voucher  relates  receives 
consideration from the issuer44 and on what the taxable amount of that distribution service is. 

With regard to non-redeemed vouchers, for which there is again no specific provision in the 
Voucher Directive, Member States are split on which specific guidance on their VAT treatment 
was provided.  

In reply to the survey’s open questions (see Annex for the synopsis report), only a minority of 
Member  States  raised  specific  issues  with  the  application  of  the  current  rules.  The  main 
problems identified related to issues already being discussed by the VAT Committee such as 
the qualification of an instrument as a voucher and then, once the existence of a voucher has 
been established, to the distinction between SPVs and MPVs. Other issues pertained to the 
application of the current rules, such as cross-border trade in vouchers (which has recently 
been the focus of a judgment by the CJEU) and the calculation of the taxable amount, especially 
for  the  redemption  of  MPVs  and  related  distribution  services,  or  related  to  non-regulated 
aspects of the legislation, such as the handling of non-redeemed vouchers. A summary of the 
most relevant ones is set out below. 

Voucher definition and qualification 

-  Cross-border  redemption  and  voucher  distribution  were  raised  by  seven  Member 
States.  Five  Member  States  mentioned  the  problem  of  qualifying  a  voucher  as  an  SPV 
where cross-border transactions are involved (on the difficulty in distinguishing between 
SPVs and MPVs, the Finanzamt O (Bons à usage unique) case was mentioned). Of these 
Member States, two mentioned the issue of a statutory change in the tax rate or a change in 
the  place  of  supply  after  an  SPV  is  issued. Another  one  of  them  wondered  whether  the 
qualification of a voucher as an SPV could be affected by the fact that margins are charged 
along a distribution chain so that the taxable amount changes. Finally, two Member States 
recalled  respectively  the importance of the correct  qualification of the instrument  in  the 

43   With one exception. Not the majority but almost half of Member States agreed that the provisions on ‘deemed 
supplier’ related to transfers of an SPV are clear for taxable persons, who are the suppliers of goods/services 
and are not the taxable persons who, acting in their own name, issued the SPV, in order for them to comply 
with their obligations. 

44   However, according to ten Member States the answer was “yes”. 

17 

 
 
 
context of its transfer and the complexity faced by taxable persons when it comes to SPVs 
involved in a chain of supplies. 

-  The qualification of a city card was raised by six Member States (this was, however, mostly 
before  a  set  of  guidelines45  on  related  issues  was  agreed  on  in  the  context  of  the  VAT 
Committee  –Section 3).  According  to  two  Member  States,  the  DSAB  Destination 
Stockholm case has given rise to new questions about what the definition of a voucher is. 
According to another Member State, an instrument only representing a flat rate subscription 
(unlimited use of a service in a certain period) should not constitute a voucher. One Member 
State  referred  to  the  discussions  in  the  VAT  Committee  on  city  cards  in  relation  to 
difficulties on the applicable rules on transfers of MPVs. Two Member States mentioned 
the difficulty differentiating between SPVs and MPVs (one of them also between the supply 
of services) when it comes to city cards.  

-  The  qualification  of  tokens  was  raised  by  five  Member  States.  In  this  regard,  the VAT 
Committee in its guidelines was of the view that, in principle, tokens shall not be considered 
vouchers within the meaning of the VAT Directive, although a case-by-case approach is 
appropriate when considering whether a token qualifies as a voucher. In the survey, two 
Member  States  pointed  out  that  a  case-by-case  approach  may  lead  to  non-harmonised 
application of the rules and does not guarantee legal certainty, and  three  Member States 
mentioned tokens/game keys, game activation codes sold by e-platforms and “ICO46 service 
tokens” in the context of difficulties to qualify vouchers and distinguish between SPVs and 
MPVs. 

-  Discount cards were mentioned by five Member States. According to one of them, a card 
that does not entitle to receive specific goods or services but only gives the opportunity to 
get a discount should not be qualified as voucher. Another Member State found difficulties 
in  the  qualification  of  mixed-purpose  instruments  acting  as  both  vouchers  and  discount 
cards.  Three  Member  States  found  it  difficult  to  distinguish  between  a  voucher  and  a 
discount card. 

-  Advance payments were mentioned by four Member States. One Member State raised the 
issue  of  qualification  of  advance  payments  as  SPVs,  MPVs  or  the  supply  of  services. 
Another one wondered whether a proof of advance payment could constitute a voucher. A 
third Member State provided the example of a reservation with advance payment that could 
be  modified  up  to  1  month  before  the  start  of  a  stay  and  wondered  whether  this  could 
constitute an MPV. Finally, one Member State pointed out that when an SPV is transferred, 
the payment may be wrongly treated as an advance payment for the supply. 

-  The  qualification  of  a  payment  instrument  was  raised  by  four  Member  States.  As 
mentioned  before,  after  two  papers47  and  discussions  in  the VAT  Committee,  guidelines 
were agreed that a voucher cannot be considered a payment instrument. In the survey, three 
Member  States  mentioned  the  difficult  distinction  between  vouchers  and  payment 

45   Guidelines agreed at the 122nd meeting, Working paper No 1074, Document C, taxud.c.1(2024)438498. 
46   ICO stands for Initial Coin Offering. 
47   Working  papers  No 983,  Questions  raised  following  implementation  of  the  Voucher  Directive, 
taxud.c.1(2019)7743273 and No 993, Questions raised following implementation of the Voucher Directive - 
further analysis, taxud.c.1(2020)1245810. 

18 

 
 
 
instruments,  while  one  Member  State  gave  the  example  of  ’points  used  within  a  barter 
system’ and whether they should be considered payment instruments or vouchers. 

-  Gift cards, scratch cards and pre-paid vouchers were mentioned by three Member States 
in particular with regard to the difficulty of qualifying gift cards (including those resulting 
from former shopping), pre-paid cards issued by ‘teleoperators’, pre-paid fuel cards, scratch 
cards and coupons entitling to collect goods for free. 

-  Tickets qualification was raised by two Member States in particular in relation to Recital 
5 of the Voucher Directive that clarifies that the provisions on vouchers should not trigger 
any  change  in  the VAT  treatment  of  transport  tickets,  admission  tickets  to  cinemas  and 
museums, postage stamps or similar. 

-  The relationship with special schemes and exemptions were raised by two Member States 
especially on whether the presence in the supply chain of an exempt small and medium-
sized  enterprise  (SME)  or,  on  the  contrary,  of  a  taxable  person  lacking  the  personal 
qualification  for  a VAT  exemption  (e.g.  medical  services)  could  change  the  nature  of  a 
voucher and on the qualification of a voucher as an SPV when a possible exemption for 
non-EU travellers could apply. 

VAT rules on the taxation of vouchers in the distribution chain: 

Transfer of SPVs 

-  Transfer in one’s own name. Three Member States mentioned problems with detecting 

whether a taxable person along a distribution chain acts in their own name. 

-  Transfer in the name of another taxable person was mentioned by four Member States, 
including difficulties encountered with tax obligations in the Member State of redemption 
of the voucher, with determining the taxable amount of the service provided (and to whom 
fees should be invoiced) and with determining the time of supply.  

-  The relationship with special schemes related to transfers of an SPV was mentioned by 
two Member States in relation to whether the supply of an SPV should be taxed when the 
issuer and/or the redeemer are exempted under the SME scheme and the problem of lack 
of input tax deduction in case of an exempt SME in the distribution chain. 

-  Deemed supplier rule related to transfers of an SPV was mentioned by two Member 
States  as  regards  the  challenges  to  apply  this  rule  and  the  differing  tax  administrations’ 
interpretations on the taxable amount of the supply made by the deemed supplier and the 
resultant invoicing obligations. 

Distribution of MPVs 

-  The taxable base of distribution services was raised by six Member States pointing, in 
particular, to the difficulty  in  calculating the taxable base when the  consideration is  not 
separately invoiced or if, along the chain, the voucher is distributed at  a price  below its 
nominal  value. It  was  also  clarified  that the  rule on the  difference between the nominal 
value  and  the  purchase  price  paid,  minus  the  amount  of VAT  related  to  the  distribution 
service supplied, applies if no separate fee has been arranged for the service.  

19 

 
 
-  The  distinction  between  different  supplies  was  raised  by  three  Member  States 
mentioning, in particular, the difficulty of distinguishing between the supply of an MPV 
itself and the supply of a distribution service made on behalf of another taxable person. 

-  Acting  on  someone  else’s  behalf  was  raised  by  two  Member  States  as  regards,  in 
particular, the issue of determining for whom the services are provided in a distribution 
chain with multiple intermediaries.  

- 

Invoicing obligations were raised by two Member States.  

Taxable amount upon redemption of MPVs 

In reply to the survey’s closed questions, the majority of Member States agreed/strongly 
agreed  that  the  provisions  on  the  taxable  amount  of  the  supply  of  goods  or  services 
provided  in  respect  of  an  MPV  are  clear  and  easy  to  apply  and  allow  for  the  national 
administration to provide clear guidance to taxable persons in individual situations. Almost half 
of Member States also agreed that these provisions are clear for taxable persons in order for 
them  to  comply  with  their  obligations  and  that  that  these  provisions  enable  the  national 
administration to enforce the applicable rules.  

In the context of the survey’s open questions, eleven Member States made comments on this 
issue pointing in particular to the difficulties in determining the taxable amount, especially in 
the case of city cards, or of MPVs relating to multiple goods/services, to the difficulty in having 
to deduct from the taxable amount each time the voucher is used in part and to the problem of 
vouchers  without  a  monetary  value  when  the  consideration  paid  is  unknown.  Doubts  were 
expressed as to whom ‘the consideration paid for the voucher’ refers (i.e., to the price paid by 
the customer to the last distributor, or by the issuer to the supplier). Finally, it was noted that a 
contradiction with the basic rule on the taxable amount may arise  when the rules on MPVs 
result in a different amount being taxed to the amount actually received by the supplier from 
the issuer of the voucher.  

Non-redeemed vouchers 

Six  Member  States  mentioned  issues  encountered  with  non-redeemed  vouchers,  in 
particular as regards whether or not to tax the consideration retained and not refunded and its 
possible qualification as consideration for a distribution/promotion service or an ‘availability 
service’ by the supplier to the MPV’s holder. It was also noted that the lack of regulation may 
encourage the issue of MPVs instead of SPVs in order to delay the chargeability of VAT and 
avoid payment in the case of non-redemption. 

5.  CONCLUSIONS 

Since 1 January 2019, common VAT rules on vouchers has been applied in the EU. This report, 
pursuant to Article 410b of the VAT Directive, has assessed their performance and application 
by Member States in the 4 years since the rules were first put in place (between 2019 and 2022). 

Initially, the Commission put forward a proposal with the aim of clarifying and harmonising 
the applicable VAT rules on vouchers in the absence of which Member States had developed 
uncoordinated solutions, leading to risks of double or non-taxation. Of the provisions envisaged 
in the Commission’s initial proposal, some were eventually not adopted by the Council, thus 

20 

 
 
leaving certain specific issues (e.g. payment services) not addressed by the current rules48. Over 
the past few years, however, the VAT Committee has contributed to a more uniform application 
of the new provisions, with five working papers discussed and two sets of guidelines agreed 
on by the majority of Member States in relation to vouchers and their relationship with payment 
instruments, tokens, the VAT special schemes, and city cards, thus also covering some aspects 
not addressed by the rules as adopted in the Council49.  

As regards the implementation  of the rules by Member States in  the first  4 years, no major 
problems were detected from the compliance checks in terms of formal transposition and no 
infringement procedures have been launched. The CJEU has so far only issued two judgments 
on the new rules  introduced by the Voucher Directive (concerning city cards  and the cross-
border distribution of a voucher)50.  

The results of the survey, carried out from 27 March to 9 June 2023, show that given the short 
period the VAT rules on vouchers have been applied, Member States have not had enough 
time  to  collect  evidence,  carry  out  audits,  and  formulate  a  final  judgment  on  the  general 
performance of the VAT rules on vouchers. 

However, insofar as information was available, Member States confirm that the common EU 
rules on vouchers have broadly addressed the fragmentation and complexity of applying 
VAT to various business models resulting in simpler rules and a more uniform application 
across the EU. In particular, the VAT rules on vouchers achieve their objectives by ensuring 
more uniform requirements and simpler compliance. They are also considered mostly relevant, 
insofar as information is available to Member States, as adapted to various business models 
and fit to deal with new and upcoming models and with cross-border situations. The rules on 
vouchers, as analysed in this Report, are also shown to be in line with the general VAT system. 
Finally, these rules ensure an EU added value by addressing problems of uniform application 
and of double or non-taxation across the EU51. 

As regards the  assessment  on specific rules,  the  provisions on the general  definition of a 
voucher, on the definition of SPVs and their distinction from MPVs and on the transfer 
of SPVs and MPVs are mostly seen as clear and easy to apply for national administrations, 
allowing them to provide clear guidance and to enforce the applicable rules, and as clear for 
taxable persons in order for them to comply with their obligations. 

Only a minority of Member States highlighted issues with the application of the VAT rules 
on vouchers in their replies to the survey’s open questions. On the definition of vouchers, their 
distribution chain and non-redeemed vouchers, which were the focus of this report, the issues 
most  commonly  referred  related  to  the  distinction  between  vouchers  and  other  types  of 
instruments  (e.g.  tokens)  and  between  MPVs  and  SPVs,  especially  in  the  context  of  cross-
border trade or city cards. Other issues pertain to the quantification of the taxable amount for 
services for the distribution of MPVs and for their redemption and to the  treatment of non-
redeemed vouchers52. These issues mostly concerned aspects of application of the current 
rules  and  not  new  legislative  aspects  to  be  addressed  and  were  mostly  subject  to 

48   Section 2. 
49   Section 3. 
50   Section 3. 
51   Section 4.1. 
52   Section 4.2. 

21 

 
 
 
previous/ongoing discussions in the VAT Committee (and to a recent judgment of the CJEU) 
which significantly contributed to their more uniform application. 

This  report  therefore  shows  that  the  objectives  of  the  Voucher  Directive  have  mostly  been 
achieved, while some specific issues of application still remain to be tackled. But most of all 
the report highlights that, given that only a few years have passed, most Member States do 
not yet have enough information to properly assess the performance of the VAT rules on 
vouchers.  Especially  when  asked  about  the  efficiency  of  the  current  rules  in  terms  of  the 
reduction of administrative costs for companies issuing or transferring SPVs or MPVs, and for 
tax/customs administrations, the benefits brought to the sector, the increase in the domestic and 
cross-border trade of vouchers or fraud issues, the vast majority of Member States were unable 
to provide any answers due to the lack of information at their disposal53. 

In light of the above, given the short period the VAT rules on vouchers have been applied and 
the limited data available for the assessment, it is the Commission’s view that any proposal to 
amend  the  current  rules  would  be  premature.  Furthermore,  given  the  preliminary  views 
mostly confirming the achievement of the Voucher Directive’s main objectives, a proposal 
would also be inappropriate. Only a minority of Member States raised issues that, however, 
mainly pertained to the application of the rules as they stand and that were already the subject 
of  discussions  in  the  VAT  Committee,  while  the  few  contributions  on  new  aspects  not 
addressed by the current legislation lacked enough in-depth analysis to form the basis for a new 
legislative proposal. In the Commission’s view, and as shown by the replies to the survey, the 
focus should instead be on the correct and uniform application of the rules in force, and work 
should continue in what is the most appropriate forum of the VAT Committee, whose role 
is  to  examine  questions of  application  of  VAT  provisions  and  that,  although  not  leading  to 
binding  decisions  for  Member  States,  has  proven  over  the  years  to  have  significantly 
contributed to a more uniform application of the VAT Directive.   

53   Annex – Synopsis Report. 

22 

 
 
 
 
 
ANNEX - SYNOPSIS REPORT - QUESTIONNAIRE ON THE IMPLEMENTATION OF THE VOUCHER 
DIRECTIVE (EU) 2016/1065 

The survey, aimed at Member States, ran from 27 March to 9 June 2023. All Member States 
replied to the questionnaire. 

The majority of Member States agreed/strongly agreed that: 

-  The general definition of a voucher:  

o 

is clear and easy to apply and allows for the national administration to provide 
clear guidance to taxable persons in individual situations. 

Strongly Agree 
Agree 
Neither agree nor disagree 
Disagree 
Strongly Disagree 
No available information 
No Answer 

Answers 
2 
17 
4 
4 
0 
0 
0 

Ratio 
7,41 % 
62,96 % 
14,81 % 
14,81 % 
0 % 
0 % 
0 % 

o 

is clear for taxable persons in order for them to comply with their obligations.  

Strongly Agree 
Agree 
Neither agree nor disagree 
Disagree 
Strongly Disagree 
No available information 
No Answer 

-  The definition of SPV: 

Answers 
0 
16 
8 
2 
0 
1 
0 

Ratio 
0 % 
59,26 % 
29,63 % 
7,41 % 
0 % 
3,7 % 
0 % 

o 

is clear and easy to apply and allows for the national administration to provide 
clear guidance to taxable persons in individual situations. 

Strongly Agree 
Agree 
Neither agree nor disagree 
Disagree 
Strongly Disagree 
No available information 
No Answer 

Answers 
2 
21 
2 
1 
0 
1 
0 

Ratio 
7,41 % 
77,78 % 
7,41 % 
3,7 % 
0 % 
3,7 % 
0 % 

23 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
o  and its distinction from an MPV is clear for taxable persons in order for them to 

comply with their obligations. 

Strongly Agree 
Agree 
Neither agree nor disagree 
Disagree 
Strongly Disagree 
No available information 
No Answer 

Answers 
0 
18 
4 
1 
0 
4 
0 

Ratio 
0 % 
66,67 % 
14,81 % 
3,7 % 
0 % 
14,81 % 
0 % 

-  The cumulative conditions of knowing the place of supply and the VAT due allow the 
national administration to define what is an SPV and distinguish it from an MPV  

Strongly Agree 
Agree 
Neither agree nor disagree 
Disagree 
Strongly Disagree 
No available information 
No Answer 

Answers 
2 
22 
2 
1 
0 
0 
0 

Ratio 
7,41 % 
81,48 % 
7,41 % 
3,7 % 
0 % 
0 % 
0 % 

-  The provision on transfers of an SPV by taxable persons acting in their own name:  

o 

is clear and easy to apply and allows for the national administration to provide 
clear guidance to taxable persons on the different taxable events in individual 
situations. 

Strongly Agree 
Agree 
Neither agree nor disagree 
Disagree 
Strongly Disagree 
No available information 
No Answer 

Answers 
2 
21 
3 
1 
0 
0 
0 

Ratio 
7,41 % 
77,78 % 
11,11 % 
3,7 % 
0 % 
0 % 
0 % 

o  enables  the  national  administration  to  enforce  the  applicable  rules  on  the 

different taxable events in individual situations.  

Strongly Agree 
Agree 
Neither agree nor disagree 
Disagree 
Strongly Disagree 
No available information 
No Answer 

24 

Answers 
3 
17 
5 
0 
0 
2 
0 

Ratio 
11,11 % 
62,96 % 
18,52 % 
0 % 
0 % 
7,41 % 
0 % 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
o  are  clear  for  taxable  persons  acting  in  their  own  name  in  order  for  them  to 

comply with their obligations on different taxable events. 

Strongly Agree 
Agree 
Neither agree nor disagree 
Disagree 
Strongly Disagree 
No available information 
No Answer 

Answers 
1 
18 
4 
2 
0 
2 
0 

Ratio 
3,7 % 
66,67 % 
14,81 % 
7,41 % 
0 % 
7,41 % 
0 % 

-  The provision on transfers of an SPV when the supplier of goods/services is not the 

taxable person who, acting in their own name, issued the SPV:  

o 

is clear and easy to apply and allows for the national administration to provide 
clear guidance to taxable persons on the application of the ‘deemed supplier’ 
rule in individual situations.  

Strongly Agree 
Agree 
Neither agree nor disagree 
Disagree 
Strongly Disagree 
No available information 
No Answer 

Answers 
3 
17 
6 
0 
0 
1 
0 

Ratio 
11,11 % 
62,96 % 
22,22 % 
0 % 
0 % 
3,7 % 
0 % 

o  enables  the  national  administration  to  enforce  the  ‘deemed  supplier’  rule  in 

individual situations. 

Strongly Agree 
Agree 
Neither agree nor disagree 
Disagree 
Strongly Disagree 
No available information 
No Answer 

Answers 
3 
13 
8 
0 
0 
3 
0 

Ratio 
11,11 % 
48,15 % 
29,63 % 
0 % 
0 % 
11,11 % 
0 % 

25 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
-  The provision on transfers of an SPV by a taxable person acting in the name of another 

taxable person:  

o 

is clear and easy to apply and allows for the national administration to provide 
clear guidance to taxable persons on the different taxable events in individual 
situations. 

Strongly Agree 
Agree 
Neither agree nor disagree 
Disagree 
Strongly Disagree 
No available information 
No Answer 

Answers 
5 
16 
3 
1 
0 
2 
0 

Ratio 
18,52 % 
59,26 % 
11,11 % 
3,7 % 
0 % 
7,41 % 
0 % 

o  enables  the  national  administration  to  enforce  the  applicable  rules  on  the 

different taxable events in individual situations. 

Strongly Agree 
Agree 
Neither agree nor disagree 
Disagree 
Strongly Disagree 
No available information 
No Answer 

Answers 
3 
16 
5 
0 
0 
3 
0 

Ratio 
11,11 % 
59,26 % 
18,52 % 
0 % 
0 % 
11,11 % 
0 % 

o  are  clear for taxable persons  acting in  the name  of another  taxable person in 

order for them to comply with their obligations. 

Strongly Agree 
Agree 
Neither agree nor disagree 
Disagree 
Strongly Disagree 
No available information 
No Answer 

Answers 
1 
16 
6 
1 
0 
3 
0 

Ratio 
3,7 % 
59,26 % 
22,22 % 
3,7 % 
0 % 
11,11 % 
0 % 

-  The provision  on transfers of  an MPV by taxable persons actually  handing over the 
goods/providing  the  services  is  clear  and  easy  to  apply  and  allows  for  the  national 
administration to provide clear guidance to these taxable persons according to which 

26 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
each transfer of an MPV before the actual supply of the goods or services is out of scope 
and only its redemption against the actual supply of goods/services is subject to VAT.  

Strongly Agree 
Agree 
Neither agree nor disagree 
Disagree 
Strongly Disagree 
No available information 
No Answer 

Answers 
3 
19 
4 
0 
0 
1 
0 

Ratio 
11,11 % 
70,37 % 
14,81 % 
0 % 
0 % 
3,7 % 
0 % 

-  The provision on transfers of an MPV by taxable persons other than the taxable person 
actually handing over the goods/providing the services is clear and easy to apply and 
allows for the national administration to provide clear guidance to these taxable persons 
on the existence of any supply of services, such as distribution or promotion services.  

Strongly Agree 
Agree 
Neither agree nor disagree 
Disagree 
Strongly Disagree 
No available information 
No Answer 

Answers 
2 
16 
6 
2 
0 
1 
0 

Ratio 
7,41 % 
59,26 % 
22,22 % 
7,41 % 
0 % 
3,7 % 
0 % 

-  The provision on transfers of an MPV:  

o  enables the national administration to enforce the applicable rules in individual 

situations.  

Strongly Agree 
Agree 
Neither agree nor disagree 
Disagree 
Strongly Disagree 
No available information 
No Answer 

Answers 
2 
14 
9 
0 
0 
2 
0 

Ratio 
7,41 % 
51,85 % 
33,33 % 
0 % 
0 % 
7,41 % 
0 % 

o  are clear for taxable persons in order for them to comply with their obligations. 

Strongly Agree 
Agree 
Neither agree nor disagree 
Disagree 
Strongly Disagree 
No available information 
No Answer 

Answers 
1 
17 
4 
2 
0 
3 
0 

Ratio 
3,7 % 
62,96 % 
14,81 % 
7,41 % 
0 % 
11,11 % 
0 % 

27 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
-  The  primary  rule  according  to  which  the  taxable  amount  of  the  supply  of  goods  or 
services provided in respect of an MPV shall be equal to the consideration paid for the 
voucher is clear and easy to apply and allows for the tax administration to provide clear 
guidance to taxable persons in individual situations.  

Strongly Agree 
Agree 
Neither agree nor disagree 
Disagree 
Strongly Disagree 
No available information 
No Answer 

Answers 
2 
16 
4 
4 
0 
1 
0 

Ratio 
7,41 % 
59,26 % 
14,81 % 
14,81 % 
0 % 
3,7 % 
0% 

-  The secondary rule according to which the taxable amount of the supply of goods or 
services provided in respect of an MPV shall be equal to the monetary value indicated 
on the multi-purpose voucher itself, or in the related documentation is clear and easy to 
apply and allows for the tax administration to provide clear guidance to taxable persons 
in individual situations.  

Strongly Agree 
Agree 
Neither agree nor disagree 
Disagree 
Strongly Disagree 
No available information 
No Answer 

Answers 
2 
14 
7 
2 
0 
2 
0 

Ratio 
7,41 % 
51,85 % 
25,93 % 
7,41 % 
0 % 
7,41 % 
0 % 

-  The distribution of MPVs by a taxable person, other than the issuer of the voucher, is a 

supply of a service for the purposes of the VAT Directive. 

Yes 
No 
No available information 
No Answer 

Answers 
23 
2 
2 
0 

Ratio 
85,19 % 
7,41 % 
7,41 % 
0 % 

-  The taxable amount of the  distribution service of an MPV is  equal  to  the difference 
between the nominal value of the voucher and the purchase price paid, less the amount 
of VAT related to the supplied distribution service. 

Yes 
No 
No available information 
No Answer 

Answers 
19 
4 
4 
0 

Ratio 
70,37 % 
14,81 % 
14,81 % 
0 % 

28 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
17 Member States provided specific guidance on the distribution chain of MPVs, mostly in 
form of administrative guidance. 

Yes 
No 
No Answer 

Legislation 
Administrative guidelines 
Individual Ruling 
Other 
No Answer 

Answers 
17 
10 
0 

Ratio 
62,96 % 
37,04 % 
0 % 

Answers 
2 
12 
2 
1 
10 

Ratio 
7,41 % 
44,44 % 
7,41 % 
3,7 % 
37,04 % 

Almost half of Member States agreed/strongly agreed that: 

- 

the provisions on ‘deemed supplier’ related to transfers of an SPV are clear for taxable 
persons, who are the suppliers of goods/services and are not the taxable persons who, 
acting  in  their  own  name,  issued  the  SPV,  in  order  for  them  to  comply  with  their 
obligations. 

Strongly Agree 
Agree 
Neither agree nor disagree 
Disagree 
Strongly Disagree 
No available information 
No Answer 

Answers 
2 
11 
7 
0 
0 
7 
0 

Ratio 
7,41 % 
40,74 % 
25,93 % 
0 % 
0 % 
25,93 % 
0 % 

29 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
- 

the  provision  on  the  taxable  amount  of  the  supply  of  goods  or  services  provided  in 
respect of an MPV enables the national administration to enforce the applicable rules 
in individual situations. 

Strongly Agree 
Agree 
Neither agree nor disagree 
Disagree 
Strongly Disagree 
No available information 
No Answer 

Answers 
2 
10 
10 
2 
0 
3 
0 

Ratio 
7,41 % 
37,04 % 
37,04 % 
7,41 % 
0 % 
11,11 % 
0 % 

- 

the provisions related to the taxable amount of the supply of goods or services provided 
in respect of an MPV are clear for taxable persons in order for them to comply with 
their obligations on different taxable events.  

Strongly Agree 
Agree 
Neither agree nor disagree 
Disagree 
Strongly Disagree 
No available information 
No Answer 

Answers 
0 
13 
4 
2 
0 
8 
0 

Ratio 
0 % 
48,15 % 
14,81 % 
7,41 % 
0 % 
29,63 % 
0 % 

Half/the majority of Member States did not have enough information on: 

-  whether the distribution of free discount vouchers by a taxable person, other than the 
issuer of the voucher, where the taxable person supplying the goods or services to which 
the voucher relates receives consideration from the issuer, is a supply of a redemption 
service for the purposes of the VAT Directive. 

Yes 
No 
No available information 
No Answer 

Answers 
10 
3 
14 
0 

Ratio 
37,04 % 
11,11 % 
51,85 % 
0 % 

30 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
-  whether  the  taxable  amount  of  the  distribution  service  of  free  discount  vouchers  as 
above is equal to the price reduction granted to the customer and reimbursed by the 
issuer, less the amount of VAT related to the supplied redemption service. 

Yes 
No 
No available information 
No Answer 

Answers 
5 
5 
17 
0 

Ratio 
18,52 % 
18,52 % 
62,96 % 
0 % 

Split views were expressed on whether Member States provided specific guidance on the VAT 
treatment  of  non-redeemed  SPVs  or  MPVs.  If  yes,  guidance  was  provided  mostly  with 
administrative guidelines. 

Yes, but only for SPVs 
Yes, but only for MPVs 
Yes, for both SPVs and MPVs 
No 
No Answer 

Legislation 
Administrative guidelines 
Individual Ruling 
Other 
No Answer 

Answers 
4 
5 
8 
10 
0 

Answers 
1 
13 
2 
1 
10 

Ratio 
14,81 % 
18,52 % 
29,63 % 
37,04 % 
0 % 

Ratio 
3,7 % 
48,15 % 
7,41 % 
3,7 % 
37,04 % 

31 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
ASSSESSMENT  OF  THE  IMPACTS  OF  THE  IMPLEMENTATION  OF  THE 
VOUCHER DIRECTIVE  

The majority of Member States agreed  that the implementation  of the Voucher Directive 
over the first four years has led, at least to some extent, to: 

- 

simpler compliance 

Not at all 
Minor 
Moderate 
Large extent 
No available information 
No Answer 

-  more uniform requirements 

Not at all 
Minor 
Moderate 
Large extent 
No available information 
No Answer 

-  VAT rules adapted to various business models 

Not at all 
Minor 
Moderate 
Large extent 
No available information 
No Answer 

Answers 
1 
3 
11 
2 
10 
0 

Ratio 
3,7 % 
11,11 % 
40,74 % 
7,41 % 
37,04 % 
0 % 

Answers 
1 
4 
9 
7 
6 
0 

Ratio 
3,7 % 
14,81 % 
33,33 % 
25,93 % 
22,22 % 
0 % 

Answers 
1 
4 
9 
4 
9 
0 

Ratio 
3,7 % 
14,81 % 
33,33 % 
14,81 % 
33,33 % 
0 % 

Almost half of Member States agreed, to some extent, but the other half/almost half did 
not have enough information on whether the VAT rules: 

-  provided benefits to the tax/customs administration 

Not at all 
Minor 
Moderate 
Large extent 
No available information 
No Answer 

Answers 
3 
2 
6 
3 
13 
0 

Ratio 
11,11 % 
7,41 % 
22,22 % 
11,11 % 
48,15 % 
0 % 

32 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
- 

fit to deal with new and upcoming business models 

Not at all 
Minor 
Moderate 
Large extent 
No available information 
No Answer 

- 

fit to deal with cross-border situations 

Not at all 
Minor 
Moderate 
Large extent 
No available information 
No Answer 

Answers 
1 
5 
5 
3 
13 
0 

Ratio 
3,7 % 
18,52 % 
18,52 % 
11,11 % 
48,15 % 
0 % 

Answers 
2 
3 
6 
2 
14 
0 

Ratio 
7,41 % 
11,11 % 
22,22 % 
7,41 % 
51,85 % 
0 % 

The majority of Member States did not have enough information on whether the VAT rules: 

- 

resulted in the reduction of administrative cost for: 

o  companies issuing SPVs 

Not at all 
Minor 
Moderate 
Large extent 
No available information 
No Answer 

o  companies issuing MPVs 

Not at all 
Minor 
Moderate 
Large extent 
No available information 
No Answer 

Answers 
1 
0 
2 
1 
23 
0 

Ratio 
3,7 % 
0 % 
7,41 % 
3,7 % 
85,19 % 
0 % 

Answers 
2 
0 
1 
1 
23 
0 

Ratio 
7,41 % 
0 % 
3,7 % 
3,7 % 
85,19 % 
0 % 

33 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Answers 
1 
0 
0 
1 
25 
0 

Ratio 
3,7 % 
0 % 
0 % 
3,7 % 
92,59 % 
0 % 

Answers 
1 
0 
0 
1 
25 
0 

Ratio 
3,7 % 
0 % 
0 % 
3,7 % 
92,59 % 
0 % 

Answers 
4 
1 
1 
2 
19 
0 

Ratio 
14,81 % 
3,7 % 
3,7 % 
7,41 % 
70,37 % 
0 % 

Answers 
0 
1 
1 
1 
24 
0 

Ratio 
0 % 
3,7 % 
3,7 % 
3,7 % 
88,89 % 
0 % 

o  companies transferring SPVs 

Not at all 
Minor 
Moderate 
Large extent 
No available information 
No Answer 

o  companies transferring MPVs 

Not at all 
Minor 
Moderate 
Large extent 
No available information 
No Answer 

o 

tax/customs administrations 

Not at all 
Minor 
Moderate 
Large extent 
No available information 
No Answer 

- 

resulted in the increase of: 

o  domestic trade of vouchers 

Not at all 
Minor 
Moderate 
Large extent 
No available information 
No Answer 

34 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
o  cross-border trade of vouchers 

Not at all 
Minor 
Moderate 
Large extent 
No available information 
No Answer 

-  provided benefits to the sector 

Not at all 
Minor 
Moderate 
Large extent 
No available information 
No Answer 

- 

addressed issues of fraud 

Not at all 
Minor 
Moderate 
Large extent 
No available information 
No Answer 

Answers 
0 
0 
1 
1 
25 
0 

Ratio 
0 % 
0 % 
3,7 % 
3,7 % 
92,59 % 
0 % 

Answers 
0 
1 
4 
2 
20 
0 

Ratio 
0 % 
3,7 % 
14,81 % 
7,41 % 
74,07 % 
0 % 

Answers 
2 
1 
2 
1 
21 
0 

Ratio 
7,41 % 
3,7 % 
7,41 % 
3,7 % 
77,78 % 
0 % 

35 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
In reply to the survey’s open questions, a minority of Member States raised specific issues 
with  the application of the current  rules.  Below  is  a graph  showing  the number of Member 
States having raised issues in reply to each open question. 

Below are four graphs with the summary of the most relevant issues raised relating to vouchers 
definition/qualification,  distribution  chains  and  non-redeemed  vouchers  with  the  number  of 
Member States that have raised the issues. This analysis takes into account all the replies to the 
different questions in the questionnaire to provide the most complete overview of the issues 

36 

 
 
 
raised (e.g., the first graph includes qualification issues even if mentioned by a Member State 
in the context of a question not directly related to the definition of vouchers). 

37 

 
 
 
 
38