Several factors contributed to the FFMDB’s decision to delay implementation of the reform, including:
- Large Enterprise Unprepared: About 25% of Large Enterprises reported that they were not ready for the 2024 deadline, which raised concerns about the successful transition.
- Late PDP registration: The late registration of PDPs compared to the planned effective date has created logistical and administrative challenges.
- Complexity of the pilot phase: The pilot phase was more complicated than expected due to the large number of 1,300 companies applying, requiring more time for in-depth testing.
- Problems with understanding e-reporting: A lack of understanding of the e-reporting system was also identified as an obstacle to the rapid implementation of the reform.
- Initial summer calendar: The initial launch planned for mid-summer was deemed inappropriate for a smooth transition.
- PPF Not Ready: A crucial point to note is that the PPF will only be operational from fall 2024, which made implementation in July impossible.
There are still new deadlines being considered. Indeed, PBIF is currently considering a new timetable for the implementation of the reform, taking into account the development of the FPP in 2024. The time frames envisaged are:
- 2025 – An expanded pilot phase of one year will be implemented, allowing for more in-depth testing.
- 2026 – The roll-out of the deferred tax reform will be in two or three phases, with the possibility that it will spill over into 2027. The ideal dates for these phases would be March and October 2026.
The new timetable for implementing the deferred tax reform will likely be announced in early October. However, it is important to note that additional legislative work will be required to clarify certain elements. For example, the registration of PDPs will be allowed without requiring interoperability tests with PPF, otherwise companies will not be able to anticipate their choice of PDPs. This legislative work is planned for the first quarter of 2024, ensuring a more fluid implementation of the tax reform.
In conclusion, the DGIP’s postponement of tax reform is accompanied by strong reasons, aimed at ensuring a smooth and efficient transition for all stakeholders. The new timelines envisaged offer a realistic prospect for successful implementation of this important reform.
