Gemeinsame Stellungnahme von EKD-Büro und der Church and Society Commission der Konferenz Europäischer Kirchen zur "Überprüfung der bestehenden Gesetzgebung zu ermäßigten Mehrwertsteuersätzen"

Joint Conribution

As the Protestant Church in Germany (EKD) and Church and Society Commission (CSC) of the Conference of European Churches (CEC) we welcome the online consultation launched by the European Commission to ascertain the views of the public and businesses on the review of the existing legislation on VAT reduced rates.

As churches in Europe, we are responsible for much of the renovation, restoration, alteration, repair, maintenance and cleaning of numerous historic places of worship. As such, we are responsible for preserving the cultural and spiritual heritage of the EU, bearing in many cases the financial burden to fulfil this responsibility for the common good.

We will limit our response to the above-mentioned issue and to questions 5 and 6 of the questionnaire:

5) “What is your view on the reasoning developed under chapters 3 to 6 regarding labour intensive services, locally supplied services, housing and restaurants and the possible extension of the possibility to apply reduced rates to all these services?“

6) “Are there any additional arguments in favour or against the measure of reduced rates in this respect?”

As churches we are in favour of extending the possibility for Member States to apply reduced rates to similar services not listed in annex IV of Council directive 2006/112/EC, where there is no impact on the proper functioning of the internal market. Therefore we welcome that as an example of locally supplied services “renovation, alteration, repair, maintenance and cleaning of places of worship, schools, or other non commercial buildings” is mentioned in the consultation document of the European Commission (p.5).

Concerning the list of requests of new sectors to be added to the future ANNEX III of directive 2006/112/EC (p. 11) we welcome that

-repair of churches and other places of worship as well as

-repair, restoration and maintenance of cultural heritage and historical monuments

are included, but would prefer a more extensive formulation with regard to places of worship including renovation, alternation, maintenance and cleaning, but restoration as well.

Furthermore, we strongly agree that it would appear justified to include in the 2008 Commission proposal a definitive provision enabling Member States to apply reduced rates, at the level provided for in the current Community legislation, to the range of locally supplied services to places of worship and listed monuments as mentioned above: renovation, alteration, repair, maintenance, cleaning and restoration.

In most of the Member States, churches have responsibility for the preservation of historic places of worship and other historic buildings in care of the churches. They have to spend large sums of money in fulfilling this responsibility. Many churches find the financial burden increasingly onerous, particularly smaller churches that depend largely or entirely on the regular donations of their members.

To provide for the possibility of reduced VAT rates on, for example, preservation and conservation works on historic places of worship and other historic buildings would be a strong and positive political signal to encourage churches to preserve Europe’s cultural heritage. This heritage serves the common good, for example as a valuable educational resource. Moreover, historic churches and other places of worship provide for the regional identity and the economic prosperity of the places where these buildings are located. They often attract visitors and tourists, thereby creating and sustaining employment. Reduced VAT rates for such purposes would also have positive effects on the local economy by creating jobs in the construction and especially preservation, craft and restoration sector. These arguments are supported by environmental considerations; these should promote systems of taxation that encourages conservation, re-use and sustainable construction techniques.

Finally, restoration and preservation works are generally labour intensive, locally provided and unlikely to distort competition in the internal market. A lower VAT rate would constitute an incentive to invest more in restoration, conservation and maintenance of important monuments. The proper maintenance of buildings is also important from a health and safety perspective, particularly in ensuring that users and passers-by are not injured due to a poorly maintained infrastructure, such as crumbling masonry.

Therefore we actively and strongly support the European Commission in its approach to allow Member States apply reduced VAT rates to these kinds of activities.

The Conference of European Churches (CEC) is a fellowship of some 120 Orthodox, Protestant, Anglican and Old Catholic Churches from all countries of Europe, plus 40 associated organisations. CEC was founded in 1959. It has offices in Geneva, Brussels and Strasbourg. The Church and Society Commission of CEC links member churches and associated organisations of CEC with the European Union’s institutions, the Council of Europe, the OSCE, NATO and the UN (on European matters). Its task is to help the churches study church and society questions from a theological and social-ethical perspective, especially those with a European dimension, and to represent common positions of the member churches in their relations with political institutions working in Europe.

The Evangelical Church in Germany (EKD) is one of CEC’s largest member churches representing 23 Protestant regional member churches across Germany and bringing together around 26 million people from the Lutheran, Reformed and United traditions The EKD Brussels office maintains a special cooperation with CSC on legal matters.