Summary of comments:
• Swedish Enterprise is essentially in favour of the directive being revised and modernised to adapt to climate goals and strengthen healthy competition within the Union. At the same time, it is important that companies’ competitiveness is not undermined. To support the climate and emissions pricing, it would have been preferable to incorporate a mandatory carbon tax component into the directive.
• The consequences of the proposals for Swedish business are too unclear and therefore a thorough impact assessment must be made regarding companies’ energy taxation and competitiveness. Furthermore, no impact assessment has been published for how the various proposals within the “Fit for 55” framework collectively affect business conditions for companies.
• Swedish Enterprise shares the Swedish government’s position that member states must continue to be given the opportunity to tax electricity and fuels differently depending on where and how fuel is used. Due to this, it is important that the government works to ensure that it is also possible to continue to be able to tax commercial consumption at the EU minimum tax rate within the framework of the directive.
• The proposed ranking of different fuels according to environmental performance can be challenging and have distortive effects.
• Sustainable biofuels should continue to be exempt from taxation.
• Exemptions and reductions should be used primarily to promote EU competitiveness and to avoid carbon leakage, not for social policy purposes such as energy poverty.
• Swedish Enterprise agrees with the government’s position that Sweden should not support any Commission proposal for a transition from unanimity to qualified majority voting in the EU on tax. It is important to safeguard national sovereignty on tax issues.
• The proposed implementation deadline for member states of 1 January 2023 is unreasonably short.
• The unanimity requirement gives the government a veto. Sweden has every opportunity to push for important changes to the proposed directive, an opportunity that must be used in order not to worsen conditions for companies in Sweden.