Fabian Demicoli

Proposal on Limits on Cash Transactions GRTU submits feedback following consultation with members

Following an information session held by FIAU and the Ministry of Finance, hosted by GRTU to its members from various sectors, GRTU opened a two-week consultation period to its members. The main scope of the proposal is to set a limit upon cash transactions which is being suggested to be at €10,000 for cases of both single transactions as well as transactions which appear to be linked. Any such transactions above this threshold would be considered illegal and penalties duly applied.

GRTU appreciates this positive initiativewhich is aimed at combating tax evasion and money laundering as well as incentivising the shift towards other safer and more contemporary methods of payment such as online transactions. GRTU has however put forward a feedback document highlighting the following concerns:

  1. Linked Transactions—Members from specific sectors are concerned with such cases based on agreements over periods, such as in the case of vehicle hire purchase.
  2. Communication and Dissemination—A strong information campaign to the general public is necessary as it is unfair to place this onus on the trader.
  3. Monitoring—If this proposal is to be implemented appropriate monitoring is necessary. If not, it is clear that this would result in a situation where mass non-compliance would work against complying retailers.
  4. Arbitrary Regulations—Interpretation of linked transactions should be based on an arbitrary set of regulations and not reliant on subjectiveness.
  5. Retailer Protection and Payment Assurance— Compliant traders that do not accept such cash transactions and make the necessary reports need to be protected and assured payment.
  6. Donations—Donations also need to be regulated as otherwise these can be used as a loophole to the scope of this regulation.


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