(4a)

Although the COVID-19 outbreak creates genuine difficulties for national administrations, it should not be used as an excuse to further delay the implementation of commonly agreed rules. Before the outbreak, some Member States had signalled that they would encounter delays in the implementation of the new system. Beyond the immediate difficulties linked to the COVID-19 outbreak, governments should spare no efforts to implement the new system. Member States which are facing issues which could cause a delay in the full implementation of the rules should use the technical assistance provided by the Commission to ensure correct and complete implementation of the e-commerce package. The e-commerce package’s goals of facilitating the global competitiveness of European SMEs, easing the administrative pressure on Union sellers and ensuring that online platforms contribute to a fairer VAT collection system while combatting tax fraud are key aspects of a level playing field for all businesses, which is particularly important in the context of the post-COVID-19 recovery.

(5)

Taking into consideration the challenges that Member States are facing to tackle the COVID-19 crisis and the fact that the new provisions are based on the principle that all Member States have to update their IT systems in order to be able to apply the provisions laid down in Regulation (EU) 2017/2454, thus ensuring the collection and transmission of information and payments under the modified schemes, it is necessary to postpone the dates of application of this Regulation by six months. A postponement of six months is appropriate, because the delay should be kept as short as possible to minimise additional budgetary losses for Member States.

(5)

Taking into consideration the new challenges faced by Member States as a result of the COVID-19 outbreak and the fact that the new provisions are based on the principle that all Member States have to update their IT systems in order to be able to apply the provisions laid down in Regulation (EU) 2017/2454, thus ensuring the collection and transmission of information and payments under the modified schemes, it might be necessary to postpone the dates of application of this Regulation by three months. Postponement is not desirable, as it will lead to a loss of revenue and an increased VAT gap, while prolonging unfair competition between non-EU and Union sellers. However, a postponement of three months might be appropriate as it aligns with the period of lockdown across most Member States. An even longer postponement would extend the risk of VAT fraud at a time when public finances should be replenished in order to fight the pandemic and its economic and social consequences. A longer delay of six months could lead to a loss of revenue of between EUR 2,5 billion and EUR 3,5 billion for Member States. In light of the crisis caused by the COVID-19 outbreak, it is of the utmost importance to avoid further loss of revenues.