What does this mean for other industry players? How will they act in order to avoid falling into the same situation as Stardoll AB did? On behalf of the industry, we require concise and clear answers to these very important issues where there is a great need for stringent guidance to achieve the inevitable taxation.

We are aware that the VAT issue will be discussed in the EU VAT Committee and the guidelines set by that agency may surface at some point in the spring. However, it is unlikely that these guidelines will answer all the questions that the Swedish industry has. Moreover, it is urgent to find answers. Businesses need clarification in order to adapt. In addition, there are several companies that are considering moving abroad, too, in order to avoid the uncertainty that exists today. It is therefore urgent to prevent unnecessary relocation.

Our organizations represent an entire industry of companies for which the issue of VAT management is still not resolved. We therefore call on the Swedish Tax Agency to quickly consider and present their views on how VAT should be handled in the sale of electronic services, particularly in cases where another company receives payment for the service.

For the industry's behalf, we want concrete and clear answers to these very important issues where there is a great need for stringent guidance to achieve a predictable tax system:

1. What is it that determines who is liable for sales of electronic services? Is it anyone who bills the customer or who according to the agreement is responsible to the customer for the service or are there other determining factors? In other words, when is a Swedish company tax liable for the sale of electronic services to private individuals resident in other EU countries, and when this charge is passed on to any other taxpayer?
2. If EU member states cannot agree on the issue of who is taxable, as you know, double taxation may arise. How does the Swedish Tax Agency view this situation, ie. how should companies act to avoid this situation? Should all Swedish players apply for exemption and what documentation is required in order for the Swedish Tax Agency to accept and approve an exemption application? Or does the Swedish Tax Agency believe there is another way to deal with the situation?

We look forward to an open dialogue with the Swedish Tax Agency regarding these questions.

The Swedish Games Industry, Spokesperson Per Strömbäck

The Swedish Association of Software Industry, CEO Peter Bergh

Swedish Federation of Business Owners, Tax Expert Annika Fritsch

Swedish IT & Telecom Industries, Director of the Organization Anne-Marie Fransson

PROMISE, CEO Mikael Svelch

Confederation of Swedish Experts, Tax Expert Anna Sandberg Nilsson