Fleet Taxi Services as a VAT and Income Tax "Black Hole:" Is a Memorandum with Platforms a New Instrument for Tax Administration?
Fleet Taxi Services as a VAT and Income Tax "Black Hole:" Is a Memorandum with Platforms a New Instrument for Tax Administration?

Summary/Abstract: This article analyzes tax evasion in the Czech ride-hailing sector through the so-called fleet model, in which intermediary companies (fleet partners) between the platform (Uber, Bolt) and drivers serve to disperse VAT liability. The authors identify the structural causes of the failure of existing instruments (DAC7, the unreliable-VAT-payer mechanism, securing orders) and evaluate the October 2025 Memorandum on Cooperation between the Czech Tax Administration and Bolt as a soft-law instrument. The article also examines the limits on data sharing under the GDPR, drawing on the EUR 290 million fine imposed on Uber by the Dutch data protection authority. It maps the trajectory toward the ViDA package (2028-2030) and advances five de lege ferenda proposals. The authors argue that voluntary cooperation memoranda can serve as legitimate transitional instruments, bridging the gap until the ViDA deemed-supplier rule enters into force.

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