DAC7 and Enaa – no reporting obligations
What is DAC7? Council Directive (EU) 2021/514
DAC7 is a European directive transposed into the Slovenian ZDavP-2 (Articles 79.b–79.č).
- Purpose: to increase transparency in business conducted via digital platforms.
- Platform reporting operators must report to tax authorities on sellers who sell goods or services through their platform.
Who is a platform reporting operator?
A company that administratively enables a digital platform through which third parties (sellers) can sell goods/services directly to customers.
Examples: Amazon, eBay, Booking.com, Wolt (when third parties post and sale their own listings).
When is there no reporting obligation?
- When a company sells on its website in its own name and for its own account only.
- Suppliers sell goods to the company, and the company then sells to the customer.
- The customer’s contract is always with the company (not the supplier).
- In this case, suppliers are not platform users under DAC7.
Enaa business model
- Suppliers (from Slovenia and abroad) deliver goods to us.
- We sell the goods to the end customer in our own name and for our own account.
- The customer’s contractual relationship is exclusively with us.
Therefore, our system is not a digital platform within the meaning of DAC7, but a classic online store with own-account sales.
Conclusion
- Enaa is not a platform reporting operator under DAC7.
- We are not obliged to report data on our suppliers.
- Regular tax obligations (VAT, corporate income tax, etc.) remain unchanged.