GSEVEE letter on the obligation to supply electronic payment instruments

GSEVEE sent a letter to the Deputy Minister of Finance, Mrs Papadassiou and the Secretary General for Economic Affairs. Commerce & Consumer Protection, Mr. A. Papadradakis on the obligation to supply electronic payment instruments.

In particular, the letter states that:

According to the Joint Ministerial Decision 45231/2017 (Government Gazette B 1445 / 27.4.2017), the deadline for the supply of electronic payment instruments by a large subset of craftsmen, traders and professionals is expired on 27 July 2017. However, reports of malfunctions encountered by companies in application procedures and approval of terminal equipment supply have been multiplying lately.

In particular, the reports focus on the following:

1) There are a number of seasonally-based businesses located in remote areas with low turnover and lack of access to, or supply of, suitable technological equipment due to a lack of digital infrastructure at local level. For these businesses, care should be taken to get rid of the obligation to supply electronic payment instruments for the period up to and including the full implementation of the measure. It is suggested that this provision could apply to companies in analogy with the POL for the persons required to collect receipts by electronic means (POL 1005/2017, “Taxpayers living permanently in villages with a population of up to 500 inhabitants and islands with a population below 3,100 inhabitants, according to the latest census “).

2) Banks delay or reject the terminal version when they assess that the business is not an attractive customer. Obligatory implementation of the terminal installation measure by July 27 in some occupation groups will result in fines of € 1,500, but it is unknown what happens if the fault for the non-commissioning of the terminal is borne by the banks or some other supplier. In the short term, the possibility of extending the obligation until the end of 2017 should be explored. It is proposed that banks’ written rejection of claims should be obligatory in order to provide evidence of the firm being controlled.

3) Charges remain prohibitive for certain categories of companies, as they exceed 1%, while the maintenance and supply costs of the component should be taken into account. It is proposed, for reasons of competition, to impose corporate billing thresholds (not exceeding 1%) otherwise the company may operate without having an electronic payment instrument (let’s choose to deposit in a bank account).

4) Account pledges / seizures lead companies to a reverse option, that is, a money-holding incentive is created outside the official banking sector, which negatively affects the deposit base, financial stability, tax revenues and normalization of economic relations in the market. The consequence of this is that the business, which has no bank account and has very few transactions with POS terminals (contrary to the stated objective of the tax authorities), has a distortive comparative advantage. It is proposed to implement a rigid business account, through which payroll, suppliers, asset accounts will be covered.

GSEVEE estimates that the above actions will lead directly to consolidation of confidence and restoration of the chain of transactions between businesses – banks – tax authorities, and calls on the Ministry to take the appropriate legislative initiatives.