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Payment service providers and the fight against e-commerce VAT fraud

24-10-2019

This briefing analyses the quality of the IA accompanying the Commission’s proposal to transmit payment service providers’ data to the national tax authorities of the EU Member States in order to combat cross-border e-commerce VAT fraud. The IA focuses on the economic impacts, namely the potential recovery of VAT loss by Member States, which is expected to outweigh the costs of the initiative (even though benefits and costs could not be quantified with certainty). Regional divergences are acknowledged ...

This briefing analyses the quality of the IA accompanying the Commission’s proposal to transmit payment service providers’ data to the national tax authorities of the EU Member States in order to combat cross-border e-commerce VAT fraud. The IA focuses on the economic impacts, namely the potential recovery of VAT loss by Member States, which is expected to outweigh the costs of the initiative (even though benefits and costs could not be quantified with certainty). Regional divergences are acknowledged in the IA, but not assessed. The IA also admits that a key assumption, the improved cooperation with third countries, remains uncertain (it could imply counterproductive trade diversion towards extra-EU areas).

Establishing a European Investment Stabilisation Function

17-01-2019

The European Commission has proposed to establish a European Investment Stabilisation Function. The accompanying IA focusses on the expected positive effects of the proposal, rather than providing a balanced assessment of different policy options and all their relevant impacts. The mostly qualitative analysis is complemented by some quantifications that are, to the Commission’s own admission, based on uncertain assumptions. The caveats, methods and models of the IA could have been better explained ...

The European Commission has proposed to establish a European Investment Stabilisation Function. The accompanying IA focusses on the expected positive effects of the proposal, rather than providing a balanced assessment of different policy options and all their relevant impacts. The mostly qualitative analysis is complemented by some quantifications that are, to the Commission’s own admission, based on uncertain assumptions. The caveats, methods and models of the IA could have been better explained to increase its transparency. The selection of the preferred option seems to be based on political considerations.

Enabling sovereign bond-backed securities

05-12-2018

This briefing analyses the IA accompanying the legislative proposal of the Commission to enable market-led sovereign bond-backed securities (SBBS). The problem definition and the objectives of the IA do not follow entirely the better regulation guidelines. Nevertheless, the policy options, including the baseline scenario, seem logical and pertinent, lacking, however, necessary specification and precision. The assessment focusses on direct effects on the euro-area sovereign bonds market, expecting ...

This briefing analyses the IA accompanying the legislative proposal of the Commission to enable market-led sovereign bond-backed securities (SBBS). The problem definition and the objectives of the IA do not follow entirely the better regulation guidelines. Nevertheless, the policy options, including the baseline scenario, seem logical and pertinent, lacking, however, necessary specification and precision. The assessment focusses on direct effects on the euro-area sovereign bonds market, expecting no direct social or environmental impacts. The IA does not include the mandatory 12-week public consultation nor a comprehensive cost and benefit assessment of the initiative. It also omits, without explanation, a number of relevant issues, so that it seems like a missed opportunity to provide comprehensive and transparent support to evidence-based policy making.

Reform Support Programme

23-10-2018

Among the legislative proposals for the spending programmes of the MFF 2021-2027, the European Commission has proposed to establish a Reform Support Programme for structural reforms. The IA accompanying the proposal provides a good review of the baseline scenario, the problem to tackle and the objectives to achieve. However, it concentrates on the expected positive effects of the programme, rather than assessing thoroughly the impacts of alternative options against the baseline scenario like a standard ...

Among the legislative proposals for the spending programmes of the MFF 2021-2027, the European Commission has proposed to establish a Reform Support Programme for structural reforms. The IA accompanying the proposal provides a good review of the baseline scenario, the problem to tackle and the objectives to achieve. However, it concentrates on the expected positive effects of the programme, rather than assessing thoroughly the impacts of alternative options against the baseline scenario like a standard IA. The presentation of the delivery mechanisms is mostly qualitative, with a couple of quantified references that could have been better explained and substantiated. The IA remains vague on the precise scope of the voluntary programme and several implementation details and implies that its impacts depend to a large extent on the implementation by the Member States, which makes an ex-ante assessment challenging.

Type-approval requirements for the general safety of vehicles

18-09-2018

The European Commission recently issued a legislative proposal to increase the general safety of vehicles. This briefing provides an initial analysis of the strengths and weaknesses of the impact assessment accompanying this proposal. The IA provides a thorough problem definition and presents measures to tackle it. However, the link between problem definition and the options could have been more straightforward and the analysis, including numerous simulations and quantifications based on four different ...

The European Commission recently issued a legislative proposal to increase the general safety of vehicles. This briefing provides an initial analysis of the strengths and weaknesses of the impact assessment accompanying this proposal. The IA provides a thorough problem definition and presents measures to tackle it. However, the link between problem definition and the options could have been more straightforward and the analysis, including numerous simulations and quantifications based on four different models, could have been more transparent and clear. While the IA focuses on the cost for manufacturers on the one side and the societal benefits of prevented or mitigated casualties on the other, it excludes (or only touches upon briefly) other aspects, such as macroeconomic or indirect impacts and the privacy of data as regards the use of new technologies.

European Regional Development Fund, Cohesion Fund, a cross-border mechanism and Interreg

14-09-2018

The European Commission recently issued the legislative proposals for the spending programmes of the MFF 2021-2027, including the legislative package on cohesion policy. Three of these proposals (on the ERDF and the Cohesion fund, on a new mechanism for cross-border cooperation and on Interreg) are covered by one IA. It provides a good description of policy challenges and ‘lessons learned’ from previous programmes. Potential effects of proposed measures are, however, discussed rather generally, neglecting ...

The European Commission recently issued the legislative proposals for the spending programmes of the MFF 2021-2027, including the legislative package on cohesion policy. Three of these proposals (on the ERDF and the Cohesion fund, on a new mechanism for cross-border cooperation and on Interreg) are covered by one IA. It provides a good description of policy challenges and ‘lessons learned’ from previous programmes. Potential effects of proposed measures are, however, discussed rather generally, neglecting in particular social, environmental and other specific or indirect impacts. Additional explanations regarding the assumptions (and uncertainties) underlying the analysis would have increased the completeness, precision and accountability of the IA.

Cross-border distribution of collective investment funds

27-08-2018

The European Commission recently issued a legislative proposal to increase cross-border distribution of investment funds. This briefing provides an initial analysis of the strengths and weaknesses of the impact assessment accompanying the Commission's proposal. Based on both internal and some external sources, as well as several stakeholder consultations, the impact assessment provides useful information, but lacks coherence and transparency. It acknowledges some limitations, citing lack of data ...

The European Commission recently issued a legislative proposal to increase cross-border distribution of investment funds. This briefing provides an initial analysis of the strengths and weaknesses of the impact assessment accompanying the Commission's proposal. Based on both internal and some external sources, as well as several stakeholder consultations, the impact assessment provides useful information, but lacks coherence and transparency. It acknowledges some limitations, citing lack of data and the influence of other factors, which are out of the scope of the impact assessment. The range of proposed policy options is rather limited for some areas. The impact assessment focuses on average cost effects for asset managers (and for competent authorities), without taking into account social or territorial implications and without analysing, for instance, the effects on SMEs or on the EU27 after Brexit.

Minimum loss coverage for non-performing exposures

03-07-2018

In March 2018, the European Commission presented a proposal to introduce statutory backstops for 'non-performing exposures'. These concern loans, debt securities or certain overdue off-balance-sheet items. Since the financial crisis, the EU has aimed to address the high numbers of these non-performing exposures, including in particular non-performing loans, as they risk destabilising the financial sector and thereby the EU economy. This briefing provides an initial appraisal of the quality of the ...

In March 2018, the European Commission presented a proposal to introduce statutory backstops for 'non-performing exposures'. These concern loans, debt securities or certain overdue off-balance-sheet items. Since the financial crisis, the EU has aimed to address the high numbers of these non-performing exposures, including in particular non-performing loans, as they risk destabilising the financial sector and thereby the EU economy. This briefing provides an initial appraisal of the quality of the impact assessment accompanying the Commission proposal

European crowdfunding service providers for business

29-05-2018

This briefing provides an initial analysis of the strengths and weaknesses of the European Commission's impact assessment (IA) accompanying the above-mentioned proposal, published on 8 March 2018 and referred to Parliament's Committee on Economic and Monetary Affairs (ECON). The strengthening of the capital markets to boost long-term investment in the EU is a priority EU goal. In this context, the Commission's 2017 mid-term review of the capital markets union (CMU) action plan noted that access to ...

This briefing provides an initial analysis of the strengths and weaknesses of the European Commission's impact assessment (IA) accompanying the above-mentioned proposal, published on 8 March 2018 and referred to Parliament's Committee on Economic and Monetary Affairs (ECON). The strengthening of the capital markets to boost long-term investment in the EU is a priority EU goal. In this context, the Commission's 2017 mid-term review of the capital markets union (CMU) action plan noted that access to finance for small, innovative businesses is a challenge in all EU countries, even those where access to bank finance has remained stable during the financial crisis. Start-ups and other unlisted firms lack risk finance to invest in innovation and growth, in particular in the early stages of their development (IA, p. 6, 8). In view of closing this gap and complementing bank financing, the Commission supports alternative sources of financing, including technology-enabled financial services, the largest part of which consists in crowdfunding. In this context, crowdfunding is defined as an 'open call for the collecting of resources ... from the wider public through an internet-based platform for a specific project' (IA, p. 8). A 2016 Commission staff working document noted that crowdfunding has been developing rapidly since 2013, but remained concentrated in a few EU countries, with 81 % market share in the United Kingdom (UK) (IA, p. 16). Some Member States introduced national rules to regulate their online platforms and/or apply elements of existing EU legislation on financial services to specific types of crowdfunding, while others leave some aspects of the activity unregulated. This regulatory patchwork hinders cross-border crowdfunding and creates considerable market fragmentation (IA, pp. 26-30).

Revision of the drinking water directive

27-03-2018

This note seeks to provide an initial analysis of the strengths and weaknesses of the European Commission's impact assessment (IA) accompanying the above proposal, submitted on 1 February 2018 and referred to the European Parliament's Committee on Environment, Public Health and Food Safety (ENVI).

This note seeks to provide an initial analysis of the strengths and weaknesses of the European Commission's impact assessment (IA) accompanying the above proposal, submitted on 1 February 2018 and referred to the European Parliament's Committee on Environment, Public Health and Food Safety (ENVI).

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