Public petition n°4195

Petitioner: Philippe Nowak

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The petition asks the Chamber of Deputies to extend and unify the possibility, for all taxpayers, to receive correspondence from the Luxembourg tax administrations (Direct Tax Administration, Registration Duties, Estates and VAT Authority, Customs and Excise Administration) electronically, alongside traditional paper mail. The choice between paper mail and the electronic channel would remain at the taxpayer's initiative. Luxembourg has for several years operated an eDelivery service on the MyGuichet.lu platform: subscribers receive an email notification as soon as a new document is deposited in their private space, where it can be consulted as a PDF. The service is steadily expanding: it now covers the Direct Tax Administration, the Customs and Excise Administration (road-vehicle tax), the Police Grand-Ducale, the National Health Fund, the Common Social Security Centre, the Children's Future Fund and, since February 2026, communal administrations (communal invoices). The system works and has proven its usefulness. Four significant gaps, however, remain in the area of taxation. First, eDelivery is reserved for natural persons. Companies - which receive on average around ten separate letters per year from the Direct Tax Administration alone - do not have access to it and continue to receive all their tax correspondence on paper. Second, the Registration Duties, Estates and VAT Authority is not integrated into the eDelivery service at all: all correspondence relating to VAT, registration duties and inheritance duties is sent exclusively by post. Third, coverage of the Customs and Excise Administration is limited to road-vehicle tax and does not extend to its other correspondence. Fourth, any extension to companies should be designed from the outset with groups in mind, as groups often manage the tax correspondence of several Luxembourg entities. Requiring a separate authentication device for each company would make the service unusable in practice: it should be possible to centralise, in a single private space, the correspondence of entities declared as belonging to the same group or management mandate. The Direct Tax Administration has moreover just introduced new fields in the form 500 for the identification of groups of companies: this information, already collected, could be directly reused to organise the electronic delivery of correspondence at group level. These limits raise concrete problems. Paper letters are regularly lost, particularly when companies are domiciled in buildings hosting several other companies. The administration nonetheless considers such letters as delivered, which can directly affect a taxpayer's appeal deadlines. Processing each letter separately increases the administrative burden on businesses, and the volume of paper used runs counter to the ecological transition. The infrastructure to close these gaps already exists. In addition to MyGuichet.lu, POST Luxembourg's electronic registered letter has, under Article 34 of the amended law of 14 August 2000 on electronic commerce, the same legal value as a paper registered letter within the meaning of Regulation (EU) No. 910/2014, a tool particularly suited to correspondence sensitive to appeal deadlines. Since March 2026, taxpayers can already send electronic registered mail to the Direct Tax Administration, but reciprocity in the other direction has not yet been put in place.

The reform, which would fully align with the 54-measure transformation plan announced by the Direct Tax Administration (aiming, among other things, at 85% electronic tax returns), would serve four general-interest objectives: 1. Legal certainty for taxpayers: the electronic channel provides reliable proof of dispatch and receipt, ending situations where a taxpayer bears the consequences of a letter they never received. 2. Shared benefits and administrative simplification: electronic communication is a tool whose benefits are mutual. It simplifies the work of taxpayers and their advisers, all the more so if groups can consolidate the correspondence of their different entities in one and the same space. In the longer term, the goal should be to offer taxpayers a single, user-friendly and well-structured digital platform through which they can manage all their dealings with the tax administrations in a comprehensive and organised manner: receiving correspondence, making payments, filing returns, submitting requests, exchanging documents. Such a platform could be built by reorganising MyGuichet.lu, or designed as a dedicated new tool. For the tax administrations, the electronic channel would reduce printing and postage costs, eliminate the handling of undelivered mail, speed up notifications and improve the traceability of dispatches, all of which would contribute to the efficiency of the public tax service and to the control of its operating costs. 3. Consistency with the digitalisation already under way: eDelivery already demonstrates, across seven categories of administrations, that the model works. Extending it to companies, to the Registration Duties, Estates and VAT Authority and to all letter types is the logical next step, consistent with the digital transformation ambition publicly committed to by the tax administrations. 4. Environmental responsibility: reducing the volume of paper letters would contribute to the national ecological transition. The opt-in nature of this mechanism is essential. In line with the spirit of Article 34 of the amended law of 14 August 2000 on electronic commerce - which provides that, subject to specific legal or regulatory requirements, no one may be compelled to use a qualified electronic registered delivery service - taxpayers wishing to continue receiving their tax correspondence by traditional post should retain that option.