TRAP
Let’s start this week with a little experiment.
I give you three numbers: 2 – 4 – 6
These three numbers follow a particular rule and your job is to figure out what that rule is. You can give me any other sequence of three numbers you like, and I will tell you whether it follows the rule or not.
Take a moment. 2 – 4 – 6
What do you think the rule is?
Most people will probably come up with something like: “The numbers increase by two.” So, let’s test it.
8 – 10 – 12. Yes, follows the rule.
20 – 22 – 24. Yes, also follows the rule.
100 – 102 – 104. Yes, correct again.
Well, there you go. We’ve cracked it.
Except… we haven’t.
Because we have made a very common mistake. We have been looking for examples that confirm our theory, rather than examples that could prove our theory wrong.
Try this: 2 – 5 – 6. Yes. That one is also correct, it follows the rule. And now your beautiful “increase by two” theory has just fallen apart. What is the rule?
The actual rule is much simpler: The three numbers have to be in ascending order.
1 – 37 – 900 works.
3 – 5 – 7 works.
2 – 5 – 6 works.
3 – 2 – 1 is wrong.
The experiment, known as the 2–4–6 task, is a nice demonstration of how easily our brains can fall into the trap of looking for confirmation instead of actively looking for evidence that disproves our hypothesis.
And, of course, this has absolutely nothing to do with VAT.
Except that it does.
Because I have seen this happen in VAT analysis more times than I can count.
We start with a hypothesis: “The transaction is a supply of goods.” We find something that supports it. Then we find another rule that appears to support it. And perhaps we find a court case that seems to point in the same direction.
Done. VAT treatment confirmed.
But what if, instead, we asked: “What would have to be true for this analysis to be wrong?” That is a very different question.
The problem is that finding information that confirms our conclusion feels reassuring. Finding information that destroys our conclusion feels rather annoying.
But in VAT, annoying can be useful.
Because a VAT analysis that survives an attempt to disprove it is generally much more interesting than one that merely survived an attempt to confirm it.
So perhaps the next time you are completely convinced that you have found the answer, don’t immediately look for another source that agrees with you. Try something else. Try to kill your own theory.
And if it survives?
Well…
2 – 4 – 6.
Maybe you are finally onto something.
Anyone interested in more VAT news, developments and occasional philosophical reflections on the strange similarities between tax law and everyday life can subscribe to the weekly VATupdate newsletter at VATupdate.com
If you have any comments, questions, or ideas that you want to share with us, please send us an email at [email protected] or leave a comment under the posts of this newsletter on LinkedIn.
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WORLD
E-Invoicing / E-Reporting Briefings, VAT Concepts and Global Developments
Albania: Fiscalization Briefing on Real-Time E-Invoicing and E-Reporting
- Albania’s “fiscalization” system requires real-time clearance reporting of virtually all VAT-related transactions to the tax authority, covering B2G, B2B, B2C and cross-border transactions.
- All taxable persons are in scope, including VAT-registered and non-VAT-registered businesses for B2C, public entities, intermediaries and non-resident VAT payers.
- Fully implemented by 2021; pre-filled VAT returns were introduced in 2025. Non-compliance can lead to fines and invalidation of invoices.
France: Comprehensive Briefing on the E-Invoicing and E-Reporting Mandate
- The briefing covers France’s decentralised “Y-model” with accredited platforms, extending B2G e-invoicing to domestic B2B and adding e-reporting for B2C, international B2B and payment data.
- All taxable persons established in France must receive e-invoices from 1 September 2026; large and intermediate-sized enterprises must also issue and e-report from that date.
- SMEs and micro-enterprises follow on 1 September 2027; a “soft landing” tolerance applies in 2026 for businesses demonstrating serious compliance efforts.
Germany: Briefing on the Phased B2B E-Invoicing Mandate
- Germany applies a decentralised, post-audit model: invoices are exchanged directly between parties without a central clearance platform, based on EN 16931-compliant structured data.
- Businesses must be able to receive e-invoices from 1 January 2025; standalone PDFs do not qualify as e-invoices.
- Mandatory issuance is phased in, with full mandatory issuance from 1 January 2028; transaction-based VAT reporting is intended but legislation has not yet been proposed.
Spain: Briefing on B2B E-Invoicing, VERI*FACTU and SII
- The briefing reviews Spain’s parallel regimes: B2B e-invoicing under Law 18/2022 (“Crea y Crece”), VERI*FACTU, SII real-time ledger reporting, FACe B2G e-invoicing and TicketBAI.
- Compliance with one regime does not exempt taxpayers from the others; the B2B mandate is driven primarily by late-payment control rather than VAT fraud.
- The B2B mandate uses a hybrid model with accredited private platforms and a public AEAT solution; the implementing Ministerial Order remains unpublished.
Netherlands: E-Invoicing and E-Reporting Guide
- Mandatory structured domestic B2B e-invoicing is planned from 1 July 2030, followed by domestic digital reporting from 1 July 2031, using EN 16931 rather than a national XML format.
- Businesses, particularly SMEs outside the KOR exemption, will need to move to structured invoicing; ordinary PDFs will not qualify.
- The aggregated EC Sales List is to be replaced by transaction-level reporting; many technical details, such as schemas and APIs, are still under development.
Bulgaria: SAF-T, E-Invoicing and E-Reporting Country Booklet
- The booklet covers Bulgaria’s phased SAF-T regime (large enterprises from 1 January 2026), B2G e-invoicing since 2019 and the proposed NISSEF clearance system.
- The draft would apply mainly to domestic B2B and B2G supplies by Bulgarian-established VAT-registered entities; invoices would be legally issued only after an NRA conformity code.
- Proposed start 1 January 2028 with pre-filled VAT returns; the draft is under public consultation until 23 October 2026 and may change.
Denmark: Briefing Document on Digital Reporting and E-Invoicing
- VATupdate has published a briefing document on digital reporting and e-invoicing in Denmark.
- Relevant for businesses with Danish invoicing, bookkeeping and reporting obligations.
- Published 27 September 2026 as a country-level reference document.
Norway: Briefing Document and Podcast on E-Invoicing and E-Reporting
- VATupdate has published a briefing document and podcast on e-invoicing and e-reporting in Norway.
- Relevant for businesses subject to Norwegian bookkeeping and invoicing obligations.
- Published 27 September 2026 as a country-level reference document.
Slovakia: Briefing Document and Podcast on E-Invoicing
- VATupdate has published a briefing document and podcast on e-invoicing in Slovakia.
- Relevant for businesses preparing for Slovak structured e-invoicing obligations.
- Published 26 September 2026 as a country-level reference document.
Philippines: Briefing Document and Podcast on E-Invoicing and E-Reporting
- VATupdate has published a briefing document and podcast on e-invoicing and e-reporting in the Philippines.
- Relevant for taxpayers covered by the Philippine e-invoicing mandate.
- Published 26 September 2026 as a country-level reference document.
UAE: Briefing and Podcast on E-Invoicing
- VATupdate has published a briefing and podcast on e-invoicing in the UAE, covering VAT compliance, timelines and requirements.
- Relevant for businesses in scope of the UAE e-invoicing system.
- Published 27 September 2026 as a country-level reference document.
Taiwan: E-Invoicing and E-Reporting Country Booklet
- Taiwan’s eGUI system operates a post-issuance, near-real-time CTC model: invoices are uploaded to the MOF platform within 2 days (consumers) or 7 days (businesses), without prior clearance.
- Applies to business-tax-registered entities for B2B, B2C and B2G, and to non-resident suppliers of digital services to Taiwanese consumers.
- The platform-upload duty is fully enforced from 1 July 2025; MIG 4.1 applies from January 2026; Peppol was adopted for cross-border invoicing from September 2025.
Kyrgyzstan: E-Invoicing and E-Reporting Country Booklet
- Kyrgyzstan operates a mandatory real-time clearance electronic VAT invoice (ESF) system, with XML invoices digitally signed and registered on the State Tax Service platform.
- Mandatory since 1 July 2020 for most VAT payers and general-regime taxpayers; the standard VAT rate is 12%.
- A system overhaul in 2026 aims to integrate the ESF into a broader “Taxpayer Cabinet” platform.
VAT Concepts Explained: Joint and Several Liability in the EU
- Article 205 of the VAT Directive allows Member States to make a second person, usually the customer, jointly and severally liable for unpaid VAT, subject to a “knew or should have known” test.
- Member State regimes differ widely; case law covers default interest (ALTI), combination with denial of deduction (Konreo) and continued liability after supplier insolvency (Vaniz).
- Documented, risk-based due diligence is identified as the main defence, including bank-account and register checks.
VAT Concepts Explained: Taxable Person and Economic Activity
- The article explains the concepts of taxable person and economic activity as prerequisites for VAT/GST registration and input tax recovery.
- Divergences arise for holding companies, one-off transactions and cost-sharing arrangements; misclassification can result in penalties and unrecoverable input tax.
- A four-step decision tree is provided; mandatory e-invoicing and digital reporting make classification errors more visible to tax authorities.
Briefing: EU Fixed Establishment Principles Based on ECJ Case Law
- The briefing reviews ECJ case law on “fixed establishment”, focusing on Article 44 of the VAT Directive and Article 11 of Implementing Regulation 282/2011.
- A fixed establishment requires sufficient permanence and suitable human and technical resources; group membership or a subsidiary does not automatically create one.
- A tax representative alone does not constitute a fixed establishment; economic and commercial reality is decisive.
International Non-Profits: Fixed Establishment Risks from Remote Teams
- International non-profit associations with cross-border remote teams may create a VAT fixed establishment abroad where permanence and human and technical resources exist.
- This can trigger local registration, invoicing and reporting obligations, retrospective assessments, interest and penalties.
- Overlapping VAT claims and double taxation may arise, particularly where input VAT is not fully recoverable.
VAT Treatment of Invoices to EU and Non-EU Customers
- VAT treatment of overseas invoices depends on the nature of the supply, B2B or B2C status and the statutory place-of-supply rules, not only the customer’s country.
- Zero-rated exports require customs exit and transport evidence; invoices without VAT must carry correct legal wording such as reverse charge or export references.
- Billing an overseas customer does not remove domestic VAT where the supply is taxable at home, e.g. land-related services.
E-Invoicing Explained: UBL Versus CII Under EN 16931
- EN 16931 defines one semantic data model but permits two XML syntaxes, UBL 2.1 and UN/CEFACT CII D16B.
- Businesses must manage mapping and validation for both formats, as one standard does not mean one technical format.
- The dual-syntax reality is expected to persist under ViDA.
E-Invoicing Explained: The XML Is the Invoice, the PDF Its Picture
- The explainer addresses the legal status of the structured XML invoice relative to a PDF visualisation.
- Relevant for businesses issuing or receiving structured e-invoices alongside PDF copies.
- Part of VATupdate’s “E-Invoicing & E-Reporting Explained” series.
Fiscalization Models and Common Requirements Explained
- The article describes fiscalization models and the requirements they commonly share.
- Relevant for retailers and businesses operating cash registers or point-of-sale systems across jurisdictions.
- Published 25 September 2026 as an explanatory reference.
VAT Headaches: New Series on Errors, Pitfalls and Grey Zones
- VATupdate launches a series of about thirty instalments on contested VAT issues where law, case law and audit practice diverge.
- Aimed at in-house VAT managers, advisers, auditors and finance teams.
- Themes include invoice errors and Article 203, right to deduct, scope and consideration, cross-border and place of supply, and ViDA-era digital reporting mismatches.
OECD: Digitalisation Drives Global VAT Enforcement
- Over 116 jurisdictions apply OECD-style digital trade VAT rules; 43 countries collect VAT on low-value imports at the point of sale.
- Platform liability is expanding (Chile, Saudi Arabia, Mexico); ViDA deemed-supplier rules for accommodation and passenger transport platforms apply from July 2028.
- E-invoicing and continuous reporting are becoming central; 27 jurisdictions changed VAT rates in 2025.
OECD Warns of Fragmentation in E-Invoicing and DCTR Mandates
- The OECD notes uncoordinated growth of e-invoicing and Digital Continuous Transactional Reporting, with divergent architectures and data requirements.
- Multinationals face higher compliance costs and legal uncertainty.
- ViDA cross-border B2B reporting applies from 1 July 2030; OECD guidance of January 2026 stresses interoperability.
AI Can Transform VAT Compliance but Not Replace Tax Logic
- The article discusses the role of AI in VAT compliance and its limits in replacing underlying tax logic.
- Relevant for tax and finance teams considering AI tools for VAT processes.
- Published 24 September 2026 as a commentary piece.
AI-Powered Anomaly Detection for Indirect Tax Errors
- The article discusses the use of AI-based anomaly detection to identify indirect tax errors.
- Relevant for indirect tax and finance teams reviewing data quality controls.
- Published 25 September 2026 as a commentary piece.
Food Tax Exemptions Often Miss the Poorest Households
- The article addresses the distributional effect of food tax exemptions and whether they reach the poorest households.
- Relevant for tax policy makers and professionals following VAT rate policy.
- Published 21 September 2026 as a policy commentary.
Worldwide Upcoming E-Invoicing Mandates: Chronological Overview Updated
- VATupdate has updated its chronological overview of upcoming e-invoicing mandates, implementations and changes worldwide.
- Relevant for businesses planning multi-country e-invoicing and e-reporting roadmaps.
- Updated 27 September 2026.
link: https://www.vatupdate.com/2026/09/23/e-invoicing-developments-tracker/
E-Invoicing and E-Reporting Developments in Week 39 of 2026
- VATupdate’s weekly overview of e-invoicing and e-reporting developments in the news for week 39 of 2026.
- Relevant for professionals tracking digital VAT mandates globally.
- Covers the week ending 26 September 2026.
Fall 2026 E-Invoicing Updates for France, Germany, UAE and Spain
- The article summarises autumn 2026 e-invoicing compliance updates for France, Germany, the UAE and Spain.
- Relevant for businesses with invoicing obligations in these four jurisdictions.
- Published 25 September 2026.
Europe
ViDA (VAT in the Digital Age)
ViDA 2027: Deemed Supplier, Distance-Sales Threshold and OSS Changes
- From 1 January 2027, platforms facilitating sales by non-EU suppliers become liable for VAT also where the customer is a taxable person or non-taxable legal person.
- The €10,000 threshold will count only distance sales dispatched from the supplier’s Member State of establishment, excluding sales from stock elsewhere.
- Union OSS temporarily extends to gas, electricity, heating and cooling (including EV charging); non-Union OSS covers additional services.
Revised EN 16931-1:2026 Expands VAT Data Model Ahead of ViDA
- EN 16931-1:2026, published May 2026, adds business terms for national tax rules, exemption reasons, goods/services indicators, intra-Community transactions and detailed VAT breakdowns.
- Impacts tax determination, master data, ERP mappings, validation rules and e-invoicing service provider configurations.
- EN 16931-1:2017 is formally withdrawn but remains compliant during a migration period.
IOTA Paper Proposes Data Reconciliation Procedure for the ViDA Era
- IOTA published a paper proposing an automated Data Reconciliation Procedure reconciling real-time invoice data with VAT declarations.
- Addressed to tax administrations using transaction-level data, while preserving self-declaration and due-process safeguards.
- The paper examines the “VAT borrowing” problem in the context of the EU ViDA reforms.
ECJ / CJEU / General Court
ECJ C-167/26: Opinion on When Input VAT Deduction May Be Claimed
- An opinion has been delivered in case C-167/26 on the timing of the right to claim input VAT deduction.
- Relevant for taxable persons determining the period in which deduction may be exercised.
- Status: opinion stage; the Court’s judgment is pending.
AG Kokott: I SA Judgment Seen as Undermining EU Deduction Rules
- The post addresses Advocate General Kokott’s position on the I SA judgment and its effect on EU VAT deduction rules.
- Relevant for taxable persons relying on the right to deduct input VAT.
- Published 24 September 2026.
ECJ: Loss-Making Coffee Trips Still Fall Under Special VAT Scheme
- The ECJ held that loss-making “coffee trips” still fall within the applicable special VAT scheme.
- Relevant for organisers of such trips applying the special scheme.
- Published 25 September 2026.
CJEU: Donation of Business Shares Is Not an Article 19 Transfer
- The CJEU held that a free transfer of a business to two daughters, each receiving a half share, is not a transfer of all or part of assets under Article 19 of the VAT Directive.
- The donation and later contribution in kind are separate transactions; the exclusion is interpreted narrowly.
- The Polish transfer-of-enterprise exclusion does not apply merely because the business will later be consolidated.
Pending Referral T-548/26: German De Minimis Threshold for Input VAT Adjustment
- The Munich Fiscal Court asks whether Germany’s €1,000 de minimis threshold (Sec. 44 UStDV) unlawfully blocks input VAT adjustment on switching from the flat-rate scheme to regular taxation.
- Relevant for farmers moving from the agricultural average-rate scheme.
- Compatibility with Articles 184, 185(1) and 192 of the VAT Directive is questioned.
BFH Referral: Can a Fixed Establishment Exist Without Personnel?
- The German Federal Fiscal Court referred whether a fixed establishment can exist where only equipment is present, without personnel.
- The case concerns an Austrian company running an automated sludge-drying facility at a German municipal wastewater plant.
- Particularly relevant for increasingly automated businesses.
New General Court Case T-575/26 (Société Ecurie HZ)
- A VAT reference for a preliminary ruling from the French Conseil d’État has been lodged with the General Court.
- The subject matter is value added tax; further details are not yet published.
- Lodged 5 August 2026; language of the case is French.
New Pending VAT Cases: T-555/26, T-537/26 and C-978/26
- New VAT cases have been registered: T-555/26 (Gemeinde A), T-537/26 (M Car Sofia) and C-978/26 (Rompetrol Rafinare).
- No details of the questions referred are known yet.
- Relevant for monitoring pending EU VAT litigation.
Court Agenda: Hearing in T-689/25 (James Howden) on 21 October
- A hearing is scheduled on 21 October 2026 in T-689/25 (James Howden and Co.), an Austrian case.
- The case concerns VAT exemption conditions for intra-Community supplies and the role of VAT identification numbers.
- Relevant for suppliers applying the intra-Community supply exemption.
Country-by-Country Europe
Austria
VwGH Denies Input VAT on Undocumented Recharged IT Service Fees
- The Supreme Administrative Court (Ra 2024/15/0065, 11 August 2026) denied input VAT where the recipient could not evidence that recharged IT services were actually supplied.
- Affects groups with centralised IT functions and flat-fee intercompany recharges.
- A formal invoice and general service agreement may not suffice; an arm’s-length allocation alone does not prove supply.
link: https://www.vatupdate.com/2026/09/25/no-input-tax-deduction-for-recharged-it-service-flat-fees/
VwGH: Post-Relationship Legal Costs Are Generally Overheads
- The Court (Ro 2025/13/0027, 11 June 2026) held that legal and advisory costs incurred after business relationships end are generally overheads.
- Businesses with mixed taxable and exempt activities may recover only a pro rata share.
- A direct link to earlier taxable transactions requires objective evidence that the costs formed part of their price.
link: https://www.vatupdate.com/2026/09/25/input-vat-deduction-for-subsequent-expenses/
BFG: Municipal Recharge of Cleaning Staff Costs Is a Taxable Supply
- The Federal Fiscal Court (30 June 2026) held that a municipality recharging cleaning staff costs to an association of municipalities made a supply for consideration.
- Relevant for municipalities and public bodies with personnel-sharing and cost-recharge arrangements.
- Recharging only cost, without a profit margin, did not prevent the payment being consideration.
VwGH: Minor Private Use of Company Car Not a Taxable Supply
- Providing a company car to an Austrian employee of a foreign company is not a supply for consideration where private use is minor and the arrangement mainly serves the employer.
- Such use may instead be deemed self-consumption under § 3a (1a) no. 1 Austrian VAT Act.
- Reference: VwGH, 30 June 2026, Ro 2024/15/0028.
link: https://www.vatupdate.com/2026/09/25/private-use-of-company-vehicles-and-vat-liability/
link: https://www.vatupdate.com/2026/09/24/vat-treatment-of-company-cars-used-privately/
Late Transfer Request Triggers VAT Late-Payment Surcharge
- Where VAT is settled by transferring another taxpayer’s credit, payment is deemed made only on the day the transfer request is demonstrably filed.
- Affects taxpayers settling VAT via credit rebookings between tax accounts.
- A request filed after the due date results in a late-payment surcharge under § 217 (1) BAO.
Correction of Incorrectly Invoiced VAT Takes Effect in Correction Period
- The correction of incorrectly invoiced VAT takes effect in the period in which the correction is made.
- Relevant for suppliers who have shown VAT incorrectly on invoices.
- Concerns invoice-based tax liability and invoice correction.
link: https://www.vatupdate.com/2026/09/25/invoice-based-tax-liability-and-invoice-correction/
Free Transfer of a Motorway Bridge Triggers Deemed-Supply Taxation
- The free-of-charge transfer of a motorway bridge was treated as a deemed supply subject to VAT.
- Relevant for businesses transferring assets without consideration.
- Concerns deemed-supply rules for unpaid transfers.
link: https://www.vatupdate.com/2026/09/25/tax-treatment-of-unpaid-bridge-transfer-as-deemed-supply/
Remote Pay-by-Link Not a Cash Payment for Register Purposes
- Remote pay-by-link payments are not considered cash payments for cash-register purposes.
- Relevant for businesses subject to Austrian cash-register and receipt obligations.
- Concerns the scope of fiscalization obligations.
Belgium
Chamber Accepts Bill Partially Transposing ViDA Directive
- Bill No. 56K1718001 partially transposes Directive 2025/516, clarifying cross-border B2C rules and broadening deemed-supplier rules for platforms.
- Call-off stock: goods transferred after 30 June 2028 no longer qualify; related reporting is repealed from 1 July 2029.
- General entry into force is 1 January 2027.
Parliament Approves Phased Small-Business Exemption Rise to €30,000
- The VAT exemption threshold for small businesses rises gradually from €25,000 to €30,000.
- Affects small enterprises applying the Belgian small-business exemption.
- Steps: €26,000 (2027), €27,000 (2028), €28,000 (2029), €29,000 (2030), €30,000 (2031).
Stricter Rule for Temporary Own-Goods Movements Postponed to July 2028
- Until 30 June 2028, a Belgian VAT number may still suffice for “non-transfer” treatment of temporary own-goods movements, if the other Member State accepts this.
- Affects businesses moving machinery, equipment and demonstration goods cross-border for services.
- Aligns with the ViDA transfer of own goods scheme effective 1 July 2028.
BE SAF-T Submissions via MyMinfin From October 2026
- Companies selected for audit can transmit accounting data in BE SAF-T (OECD SAF-T 2.0-based XML) through MyMinfin.
- BE SAF-T is not a mandatory periodic filing; files should be uploaded only after an express request.
- Available from October 2026; businesses should check ERP support and data mappings.
Belgium Prepares Near Real-Time E-Reporting From 2028
- Qualifying domestic B2B invoices require structured e-invoices from 1 January 2026; draft rules add near real-time e-reporting by supplier and customer from 1 January 2028.
- Special rules are expected for VAT groups, foreign customers with Belgian VAT numbers and the farmers’ scheme.
- E-reporting is expected to replace the annual client listing for in-scope businesses.
E-Invoicing: Is the PDF Still Relevant When an XML Exists?
- The article examines the role of a PDF where a structured XML e-invoice has been issued.
- Relevant for Belgian businesses exchanging structured e-invoices with PDF copies.
- Published 27 September 2026.
Belgium Considers VAT Receipt Lottery for Restaurant Bills
- Belgium is considering a lottery based on VAT receipts to turn restaurant bills into an anti-fraud tool.
- Relevant for the hospitality sector and consumers.
- Status: under consideration.
Bulgaria
Draft Law Proposes Mandatory E-Invoicing and Real-Time Reporting From 2028
- Draft amendments of 23 September 2026 propose mandatory structured B2B e-invoicing (EN 16931) and real-time reporting to the NRA, with pre-filled returns and abolition of VAT ledgers.
- Applies to Bulgarian-established VAT-registered suppliers; intra-Community and certain other supplies are excluded.
- Proposed start: 1 January 2028; invoices valid once the NRA issues a compliance code.
link: https://www.vatupdate.com/2026/09/26/bulgaria-proposes-mandatory-domestic-e-invoicing-from-2028/
link: https://www.vatupdate.com/2026/09/26/electronic-invoicing-for-domestic-supplies-to-begin-in-2028/
link: https://www.vatupdate.com/2026/09/26/bulgaria-proposes-pre-filled-vat-returns-from-january-2028/
link: https://www.vatupdate.com/2026/09/26/bulgaria-links-valid-e-invoices-to-input-vat-deduction/
Proposal to Raise VAT Registration Threshold to EUR 75,000
- Bulgaria proposes raising the VAT registration threshold to EUR 75,000.
- Affects small businesses assessing mandatory VAT registration.
- Status: proposal.
Proposed Advance VAT Registration for Sales of New Buildings and Land
- Bulgaria proposes advance VAT registration for sales of new buildings and land.
- Affects sellers of new buildings and building land.
- Status: proposal.
Proposed Wider Margin Scheme for Works of Art
- Bulgaria proposes widening the margin scheme for works of art.
- Affects dealers in works of art.
- Status: proposal.
Proposed Revised VAT Penalties and Rules for Sealing Premises
- Bulgaria proposes revised VAT penalties and new rules for sealing business premises.
- Affects VAT-registered businesses subject to enforcement measures.
- Status: proposal.
Invoice Wording Clarified for Triangular Transactions
- Bulgaria has clarified the required invoice wording for triangular transactions.
- Affects intermediaries in intra-Community triangular chains.
- Concerns invoice content requirements.
Temporary VAT Cut on Road Fuel Under Consideration
- Bulgaria is considering a temporary VAT reduction on road fuel supplies.
- Affects fuel suppliers and consumers.
- Status: under consideration.
Croatia
Free MikroeRačun Tool Upgraded for 2027 E-Invoicing Obligation
- Croatia is upgrading its free MikroeRačun application for the 2027 e-invoicing rules.
- Relevant for small businesses using the free government tool.
- Linked to the e-invoicing obligation applying in 2027.
link: https://www.vatupdate.com/2026/09/24/croatia-upgrades-free-mikroeracun-for-2027-e-invoice-rules/
Cyprus
Circular Clarifies VAT Treatment of Medical Care Services
- Cyprus has issued a circular clarifying the VAT treatment of medical and healthcare services.
- Affects healthcare providers applying the medical care exemption.
- Published in week 39 of 2026.
link: https://www.vatupdate.com/2026/09/24/cyprus-clarifies-vat-rules-for-medical-and-healthcare-services/
link: https://www.vatupdate.com/2026/09/24/cyprus-updates-vat-rules-for-medical-care-services/
Czech Republic
VAT Amendments From 2027 Advance; New Guidance on Gratuitous Supplies
- The amendment was sent for presidential signature on 11 September 2026; planned 2027 changes cover bad-debt correction limits and the debtor’s deduction-correction deadline.
- The reduced rate would extend to all non-alcoholic beverages served in catering from 1 January 2027.
- New guidance on gratuitous supplies of goods applies from 1 July 2026, clarifying existing practice.
Easements and VAT: Why They May Not Qualify as Exempt Rent
- The article explains why easements may not qualify as VAT-exempt letting of immovable property.
- Relevant for landowners, infrastructure operators and real estate businesses granting easements.
- Published 25 September 2026 as an explanatory article.
Denmark
Update: Bookkeeping System E-Invoicing Requirements Delayed to March 2027
- Requirements for registered bookkeeping systems move from 1 January to 1 March 2027; systems must support OIOUBL and Peppol BIS and generate SAF-T files.
- E-invoicing is not yet mandatory; providers must prompt users on automatic NemHandel registration with a four-week opt-out.
- A single Peppol-based specification is planned from mid-2028, with full phase-out of OIOUBL and Peppol BIS by mid-2029.
Danish Court Clarifies VAT on Land Transfers With Foundations
- A Danish court has clarified the VAT treatment of land transfers involving foundations.
- Relevant for foundations and parties to land transactions.
- Published 25 September 2026.
Estonia
Estonia: B2B Electronic Invoicing Rules and 2026 Requirements
- The article sets out Estonia’s electronic invoicing rules, B2B regulations and 2026 requirements.
- Relevant for businesses issuing or receiving invoices in Estonia.
- Covers requirements applicable in 2026.
European Union
Commission Consults on VAT Rules for Circular Economy
- The European Commission opened a public consultation on aligning VAT rules with the circular and low-emission economy.
- Covers second-hand goods, destruction of viable goods and deduction rules for business passenger cars.
- The consultation closes on 4 November 2026.
Finland
KHO: Device Protection in Equipment Leasing Not Exempt Insurance
- The Supreme Administrative Court (KHO:2026:74) held that device protection offered with equipment leasing was not a separate VAT-exempt insurance activity.
- Relevant for leasing companies bundling protection services.
- The lessor retained significant risk and did not merely pass on insurance coverage or premiums.
France
Simplified VAT Return Regime Abolished From 1 January 2027
- Under Article 38 of the 2025 Finance Law, businesses filing one annual return with semi-annual instalments move to the standard regime.
- Quarterly CA3 returns apply up to EUR 1 million prior-year (EUR 1.1 million current-year) turnover; monthly above. Transfer is automatic.
- First CA3 for January or Q1 2027; final CA12 due 4 May 2027. The farmers’ scheme is unchanged.
Start-Up Period: Must Paper or PDF Invoices Be Recreated as XML?
- A paper or PDF invoice issued because the e-invoicing channel is unavailable remains effective for payment, accounting and deduction if it covers a genuine transaction with mandatory information.
- French guidance does not appear to require systematic retrospective XML recreation; later transmission through the approved channel is preferred.
- Any later transmission must be the same invoice, avoiding duplicate deduction and reporting.
Early E-Invoicing Figures Show High Rejection Rates
- By 14 September, about 4.81 million entities had designated an approved platform; 14.4% of reported F1 flows were non-compliant, reaching 43.5% on 10 September.
- Affects all businesses receiving e-invoices and large and intermediate enterprises issuing them since 1 September 2026.
- Appointing a platform alone does not ensure compliance; master data and interoperability are critical.
Emailed PDF Invoices No Longer Meet French E-Invoicing Rules
- Emailing a standard PDF does not satisfy the new regime; invoices must be structured, machine-readable and pass through the certified platform chain.
- Accepted formats include UBL 2.1, CII and Factur-X.
- Factur-X combines a readable PDF with embedded XML data.
Updated List of Airlines Eligible for Aviation VAT Zero-Rating
- The tax administration updated, on 23 September 2026, the list of airlines meeting the Article 262 (II) (4) CGI conditions, based on 2025 traffic data.
- Covers supplies, repairs, maintenance, chartering and leasing of aircraft of airlines with at least 80% international services.
- Listed airlines need not provide individual eligibility certificates to suppliers.
link: https://www.vatupdate.com/2026/09/25/french-airlines-eligible-for-vat-attestation-exemption/
2027 Budget Proposal: Pay-TV VAT From 10% to 20%
- The finance ministry proposes raising VAT on linear pay-TV from the reduced 10% rate to the standard 20% rate in the 2027 budget.
- Canal+ estimates an annual cost of about €200 million and possible subscription price increases.
- Status: budget proposal.
Germany
Germany Outlines Roadmap for B2B Digital VAT Reporting From July 2030
- Planned path: legislative process from 2027, voluntary pilot in early 2029 and operation of a reporting system built on structured B2B e-invoices from 1 July 2030.
- From 1 January 2027, suppliers with prior-year turnover above EUR 800,000 must generally issue structured e-invoices.
- Dates reflect government planning, not enacted obligations; architecture and data requirements remain open.
Finance Ministers Back Import VAT Offsetting in VAT Return From 2030
- On 10 September 2026, the Conference of Finance Ministers endorsed declaring import VAT in the periodic return with simultaneous input VAT deduction.
- Benefits importers by removing pre-financing of import VAT through customs.
- Target availability: 1 January 2030; federal legislation and IT development are still required.
link: https://www.vatupdate.com/2026/09/22/import-vat-integration-into-periodic-vat-returns-nears-reality/
Draft Law: Mandatory Secure Cash Registers and Digital Receipts From 2028
- From 1 January 2028, businesses above €100,000 turnover would need TSE-protected cash registers (§146a AO); annual cash sales below €12,000 would be exempt.
- Electronic receipts would replace automatic paper receipts; a criminal offence for manipulation software is proposed.
- Rental cars would need distance-measuring devices connectable to a TSE.
XRechnung 4.0 Preliminary Specification Published
- Published 15 September 2026 for analysis only; aligns with EN 16931-1:2026 and adds over 50 business terms and seven business groups.
- Businesses and software providers may need to update ERP data models, mappings and validation rules.
- XRechnung 3.0 remains mandatory until at least 31 July 2027; final 4.0 materials expected spring 2027.
BMF Circular on Company Cars Provided to Employees
- The BMF circular of 3 March 2026 confirms that private-use company cars linked to employees’ work are generally a taxable barter-like transaction.
- For long-term hire, the place of supply is generally the employee’s residence, potentially creating German VAT obligations for foreign employers.
- Only genuinely free provision falls under deemed-supply rules.
BFH: Input VAT Deductible on Legal Fees for Damages Claims
- The BFH held that input VAT on legal fees to enforce compensation claims is deductible as general overheads where services are used for the business.
- Applies even where the claim arises from a planned but unexecuted business project.
- A non-taxable compensation payment does not prevent recovery.
FG Cologne: Limits of Retroactive Invoice Correction
- An invoice can be corrected retroactively only if it contained at least some recognisable description of the services supplied.
- Relevant for recipients relying on invoice corrections to preserve input VAT deduction.
- The ruling limits the Senatex/Barlis line where the original invoice was not correctable.
Exempt Lease in Business Transfer Treated as Separate Transaction
- An exempt lease of property by the transferor to the acquirer in a business transfer can be a separate transaction outside the TOGC.
- Where the acquirer uses the property for taxable activities, the transferor must adjust input VAT previously deducted.
- Relevant for deduction monitoring in business transfers involving exempt long-term leasing.
Germany Rejects Fuel VAT Cut, Opts for Energy Tax Relief
- A temporary VAT cut on petrol and diesel from 19% to 7% was rejected.
- Instead, energy tax is cut by €0.14 per litre in a €2.5 billion package.
- Expected to apply from 1 October to 31 December 2026.
EU VAT Refund Deadline of 30 September Approaches
- EU businesses can reclaim VAT paid in other Member States via the BZStOnline portal; paper applications are not accepted.
- A separate application is required for each Member State.
- The filing deadline is 30 September; applicants should keep the electronic receipt confirmation.
BMF Clarifies Key Practical E-Invoicing Questions
- The German Ministry of Finance has clarified key practical questions on e-invoicing.
- Relevant for businesses issuing and receiving domestic B2B e-invoices.
- Published 24 September 2026.
Estimating VAT Liability for Incorrect Invoices After P-GmbH II
- The article addresses estimation of VAT liability for incorrect invoices following the P-GmbH II judgment.
- Relevant for businesses that issued invoices showing incorrect VAT.
- Published 26 September 2026.
Place of Supply for Cross-Border Vehicle Use by Employees
- The article addresses determining the place of supply for vehicles provided to employees across borders.
- Relevant for employers with cross-border company-car arrangements.
- Published 26 September 2026.
Greece
Royalties From U.S. Customer Outside Scope of Greek VAT
- Services and copyright exploitation rights granted to a U.S. business customer are supplied outside Greece and not subject to Greek VAT.
- Relevant for Greek companies licensing rights to non-EU business customers.
- Invoices should be issued without Greek VAT, citing the place-of-supply rule; minimum and sales-based royalties are treated alike.
Guernsey
Amendments Propose Alternatives to Planned 3% GST
- An amendment would scrap planned GST and raise income tax from 20% to 22% for 2027 and 2028; another would make 22% permanent.
- The 22% option is expected to raise about £35 million a year, more than the proposed 3% GST.
- One amendment would keep GST at 3% until at least £20 million annual efficiency savings are achieved.
Ireland
VAT Group Territorial Scope Changes
- Ireland is changing the territorial scope of VAT groups.
- Relevant for Irish VAT groups and their members.
- Published 25 September 2026.
Italy
Construction Reverse Charge Follows ATECO 2025 Classification
- Reverse charge under Article 17 (6) (a) DPR 633/72 applies only to services still within ATECO 2025 Section F.
- Restoration of historic buildings moved to Section S (code 91.30.01).
- Such restoration services are no longer subject to reverse charge and follow ordinary VAT rules.
Ruling 175/2026: Data Centre Colocation Is Property-Related Service
- “Private cage” colocation giving exclusive use of an identifiable area is a service connected with immovable property under Article 7-quater (1) (a).
- Taxable in Italy where the data centre is located in Italy.
- Not exempt leasing; subject to standard-rate VAT.
link: https://www.vatupdate.com/2026/09/21/italian-vat-treatment-of-data-center-server-space-services/
2026 Annual VAT Return and New Automatic Assessment Power
- The annual return for 2025 is filed electronically between 1 February and 30 April 2026.
- Taxpayers with only Article 10 exempt transactions may be exempt, unless intra-Community transactions occur.
- From August 2026, unpaid VAT may be assessed automatically where the return is not filed or omits output data.
Supreme Court: Three-Year Limit for Registration Tax Refund
- A refund of registration tax paid on an act later reclassified as subject to VAT must generally be claimed within three years from payment.
- A later VAT assessment does not postpone the start of the limitation period.
- The article notes conflicting case law on analogous VAT refund issues.
Sponsorships Without Stable Pairing Treated as Advertising
- The Lombardy Regional Tax Court of Appeal annulled a 2014 assessment against an amateur sports association.
- Contracts without a stable sponsor association were advertising agreements.
- This allowed a 50% VAT deduction instead of 10%.
VAT and Customs Rules for Cross-Border Supplies With Installation
- VAT location follows the place of installation, while customs treatment follows the cross-border movement.
- Goods from another Member State installed in Italy are a domestic supply; reverse charge or Italian registration may apply.
- Exports for installation abroad depend on the contract and whether installation is ancillary.
Ex Officio VAT Number Cancellation Blocks Wage Support
- The Labour Ministry clarified that an ex officio VAT number termination under Article 35 (15-bis.1) DPR 633/72 prevents access to CIGO, CIGS and solidarity funds.
- Affects employers whose VAT numbers are cancelled following risk analysis.
- Cancellation also removes the business from the VIES database.
Supreme Court on Property Transfer Reclassified as Business Transfer
- Ordinanza No. 23040/2026 concerns a real estate transfer recharacterised by the tax authority as a transfer of a going concern.
- Relevant for parties to real estate transactions.
- A transfer of a going concern is outside the scope of VAT.
New VAT Forced Liquidation Rule: Procedure and Deadlines
- The article covers Italy’s new VAT forced liquidation rule, including procedure, deadlines and excluded credit.
- Relevant for taxpayers subject to the forced liquidation procedure.
- Published 24 September 2026.
Publicly Leased Properties: Assessing Organised Management Structure
- The article addresses the VAT relevance of publicly leased properties and the assessment of an organised management structure.
- Relevant for owners and lessors of such properties.
- Published 24 September 2026.
VAT Applies to Sale of Raw Real Estate Without Business Complex
- VAT applies to the sale of raw real estate that does not form an organised business complex.
- Relevant for sellers of undeveloped real estate.
- Published 24 September 2026.
Retention of Title Sales: VAT Accounting and Insolvency
- The article addresses VAT accounting for sales with retention of title and the effect of insolvency.
- Relevant for suppliers selling under retention-of-title clauses.
- Published 24 September 2026.
Lithuania
Draft Law Proposes Restoring 9% VAT on Residential Heating
- Draft legislation of 22 September 2026 would restore the 9% rate for heat and hot water supplied to residential premises.
- Affects energy suppliers and property managers.
- Would apply from 1 January 2027, reversing the move to 21% from 1 January 2026; subject to parliament.
Incidental Property Leasing Excluded From Registration Threshold
- A revised draft of 23 September 2026 excludes incidental leasing and supplies of immovable property, financial and insurance services from the threshold calculation.
- Applies only where transactions are incidental; the threshold is currently EUR 45,000.
- Would apply from 1 January 2027 if adopted.
New Rules for VMI Savitarna Electronic Services
- Order No. VA-58 of 4 September 2026 establishes rules for VMI Savitarna within the new MAP system.
- Replaces rules for Mano VMI and the Electronic Declaration System; users must accept rules and verify contacts at first login.
- Effective 25 November 2026.
Netherlands
Mandatory B2B E-Invoicing From July 2030, E-Reporting From 2031
- Domestic B2B e-invoicing is planned from 1 July 2030 and domestic e-reporting from 1 July 2031, aligned with ViDA.
- EN 16931 is expected to be used, with no additional national standard.
- Subject to legislation: draft law expected in 2027, completion targeted for 2028.
Tax Plan 2027: Floriculture and Balloon Rides Move to 21%
- The 9% rate is abolished for ornamental horticulture products (cut flowers, plants, Christmas trees) and balloon rides.
- Horticulture consumer prices are expected to rise about 11%; structural revenue about €305 million a year.
- Applies from 1 January 2028; for balloon rides, VAT follows the date of the ride.
Supreme Court: No Bad-Debt Relief Merely Due to Fiscal Unity
- Bad-debt relief requires a direct contractual link between the unpaid amount and the VAT-taxed supply.
- In the telecom case, unpaid consumer-credit instalments did not automatically qualify as unpaid consideration for phones.
- Referred back to the Amsterdam Court of Appeal for fact-finding under Article 29 (1) Dutch VAT Act.
Import VAT Deduction Not Automatic for Non-Owner Importers
- Under EU case law including Weindel, import VAT is deductible only with a direct link to the importer’s own taxable outputs.
- Risk areas: service providers importing client goods, group companies importing affiliates’ goods and customs representatives.
- Incorrect assessment can lead to significant additional assessments.
Court: DGA Renting Home Office to BV Is VAT Entrepreneur
- A director-shareholder leasing rooms in his home to his BV for years carries out an economic activity.
- He was included in a VAT fiscal unity with his holding and the BV.
- Treatment of the rent as salary for payroll tax did not prevent VAT entrepreneurship.
Court Allows Pro Rata Deduction on Criminal Investigation Legal Costs
- A Dutch court allowed VAT on legal and representation costs in a criminal investigation to be deducted on a pro rata basis.
- Relevant for businesses incurring legal costs in investigations.
- Published 24 September 2026.
VAT on Sale of Building Land After Tomato Business Ends
- The case concerns the VAT treatment of building land sold after a tomato-growing business ended.
- Relevant for former agricultural businesses selling land.
- A related post covers river-space policy compensation and building plots after the farm closure.
North Macedonia
Temporary VAT Cut on Specified Fuels From 18% to 10%
- The government reduced VAT on specified diesel fuels and gas oils, identified by tariff code, from 18% to 10%.
- Affects fuel suppliers, who must apply time-of-supply rules at the rate-change dates.
- Applies 15–28 September 2026; the 18% rate resumes thereafter absent a further measure.
link: https://www.vatupdate.com/2026/09/24/north-macedonia-reinstates-fuel-vat-cut-as-pump-prices-rise/
Norway
Mandatory B2B E-Invoicing From 2027; Digital Accounting by 2030
- Bookkeeping Act amendments (June 2026) require structured e-invoices to other bookkeeping-liable businesses from 1 January 2027; emailed PDFs do not qualify.
- The 2027 phase is a sending obligation for ELMA-registered recipients; the receiving obligation is deferred to 1 January 2030.
- The final mandatory 2027 format is not yet confirmed.
Full Input VAT on Cafeteria Area Under Genuine Lease
- The tax office accepted inclusion of a cafeteria area in a voluntary VAT registration for leasing, based on a genuine market-based lease.
- The lessor may deduct input VAT on construction and refurbishment costs.
- Conditional on the operator using the space in VAT-liable business.
Poland
Update: Draft Amendment Defers KSeF Penalties and Extends Reverse Charge
- A new draft VAT amendment defers KSeF penalties and extends the reverse charge.
- Affects taxpayers issuing invoices through KSeF.
- The penalty deferral is extended until the end of 2027.
link: https://www.vatupdate.com/2026/09/25/poland-extends-ksef-penalty-deferral-until-end-of-2027-2/
link: https://www.vatupdate.com/2026/09/24/poland-to-extend-ksef-e-invoicing-penalty-deferral-until-2027/
KSeF Number Required in Payment References From 2027
- From 1 January 2027, active VAT taxpayers paying other active VAT taxpayers for structured invoices must generally include the KSeF number; a collective identifier may cover multiple invoices.
- Third-party payers may be covered, but insurers paying repairers under insurance obligations are distinguished.
- Payment scenarios should be mapped before 2027.
KSeF Does Not Create Invoicing Duty for Exempt Supplies
- VAT-exempt taxpayers need not issue invoices, including in KSeF, unless the buyer requests one within the statutory deadline (Article 106b (2)).
- The ruling concerned exempt financial and insurance intermediation services.
- KSeF governs invoice form, not the underlying obligation to invoice.
KSeF Statistics: 657 Million Invoices; No Outages Recorded
- As of 2 September, 657,378,248 invoices had been issued in KSeF by 2,370,160 issuers.
- Most reported issues concern access, permissions, authentication and log-in.
- No outages triggering offline or emergency modes have occurred.
Plans for e-VAT, Pre-Filled Returns and Free Digital Cash Register
- Poland plans e-VAT with pre-filled VAT returns and a free national digital cash register.
- Affects VAT taxpayers and retailers using cash registers.
- Taxpayer review of pre-filled returns will remain essential.
link: https://www.vatupdate.com/2026/09/24/poland-plans-e-vat-and-national-e-cash-register-reform/
23% VAT Rate Approved for Selected Non-Alcoholic and Energy Drinks
- Poland has approved a 23% VAT rate for selected non-alcoholic and energy drinks.
- Affects producers, distributors and retailers of beverages.
- The increase is planned from 2027.
link: https://www.vatupdate.com/2026/09/24/poland-to-raise-vat-on-non-alcoholic-drinks-from-2027/
link: https://www.vatupdate.com/2026/09/24/polish-government-approves-package-of-excise-and-vat/
Income Tax Sanctions for White List Payment Errors Removed
- Businesses will no longer lose PIT/CIT deductibility for payments outside the VAT white list or without split payment.
- VAT consequences remain, including joint and several liability for payments outside the white list.
- The government links the change to the KSeF rollout.
Sejm Adopts VAT Amendment Easing Export Proofs and Import Procedures
- Acceptable export evidence widens to transport documents, postal confirmations and third-country customs documents.
- Centralised clearance import declarations become fully electronic; the EUR 150 low-value import procedure gains a monthly declaration.
- The person-to-person import exemption is extended to other EU destinations.
link: https://www.vatupdate.com/2026/09/21/sejm-adopts-vat-and-customs-simplification-package/
link: https://www.vatupdate.com/2026/09/22/sejm-passes-package-of-tax-amendments/
NSA: Residential-Letting Exemption Requires Residential Character
- In I FSK 2202/23 (8 July 2026), actual residential use was insufficient where premises were formally non-residential.
- The case concerned student accommodation; landlords should review register entries and invoicing.
- Housing needs, residential character and residential use must be met cumulatively.
Residential Letting to Private Individuals Remains Exempt
- Residential letting to private individuals remains VAT-exempt.
- Relevant for landlords letting housing to individuals.
- Published 24 September 2026.
NSA Resolution Limits Review of Successive Refund Extensions
- Under resolution I FPS 2/26, courts generally review only the challenged extension, not earlier unchallenged ones.
- An exception remains for fundamental defects, e.g. extensions served after the refund deadline expired.
- Businesses should treat each extension as a separate procedural event.
link: https://www.vatupdate.com/2026/09/22/nsa-court-reviews-only-the-challenged-vat-refund-extension/
NSA: Private Tuition Exemption Requires Assessment of Teaching Objectives
- The NSA issued a taxpayer-favourable judgment; an educational dimension alone is insufficient for exemption.
- Formal qualifications in the exact subject are not necessarily decisive.
- Tutors and platforms should document teaching role, subject, expertise and contractual relationships.
Sanatorium Packages Exempt; School Camps May Fall Under Margin Scheme
- A sanatorium package may be fully exempt where medical treatment is the principal service.
- School camp organisers buying in third-party services may need the travel agents’ margin scheme.
- Providers should review package design before treating bundles as exempt.
Municipal Pool Access for Outside Schools Taxed at 8%
- Paid pool access for public schools outside the municipality is a taxable service at the reduced 8% rate.
- Relevant for municipalities, operating entities and schools.
- An educational purpose does not by itself remove the transaction from VAT.
TAX FREE Regime Cannot Substitute Ordinary Export Sales
- The NSA confirmed that physical export alone does not qualify a sale for the TAX FREE traveller refund.
- Retailers must verify eligible travellers and export in personal luggage.
- Commercial-volume sales should follow ordinary export procedures.
Parents’ Council Purchases: Municipality Shown as Buyer
- A parents’ council is generally not a VAT taxpayer.
- Since VAT centralisation (1 January 2017), invoices should show the local government unit as buyer.
- The school may be listed as recipient with a note on the parents’ council.
Current Rulings on Box Diets, Hotel Catering and Collector Cards
- Box diet supplies are classified as catering (PKWiU 56) at 8%.
- A hotel may deduct VAT on restaurant services used for taxable tourism services.
- Commemorative collectors’ cards are taxed at 23%.
VAT Groups: Preparation Matters More Than Tax Rules
- The article addresses preparation for forming VAT groups in Poland.
- Relevant for related entities considering VAT grouping.
- Published 22 September 2026.
Poland VAT Update: Key Changes Businesses Should Track
- The article summarises key Polish VAT changes for businesses to track.
- Relevant for businesses with Polish VAT obligations.
- Published 24 September 2026.
Portugal
Law 48/2026 Clarifies Reduced Rate for Urban Rehabilitation Works
- The reduced rate applies to rehabilitation works in Urban Rehabilitation Areas without prior approval of an Urban Rehabilitation Operation.
- Retroactive interpretative effect to 2009 invalidates assessments based solely on a missing ORU.
- Taxpayers with pending appeals or audits may rely on the law.
Proposed Fuel and Food VAT Cuts Raise Deficit Concerns
- Opposition parties propose cutting fuel VAT from 23% to 13% and restoring zero VAT on essential foods.
- Estimated cost: about €1.2 billion (fuel) and €800 million (food) annually.
- The finance minister warned the measures could push Portugal into deficit in 2027.
link: https://www.vatupdate.com/2026/09/24/portugal-parliament-considers-temporary-vat-cut-on-road-fuels/
Russia
Draft: 22% VAT on Cross-Border Online Purchases via Platforms
- Draft Tax Code amendments for 2027–2029 set a 22% VAT rate on cross-border online purchases.
- E-commerce platforms would collect VAT as agents.
- A previous proposal phased the rate in (7% 2027, 14% 2028, 22% 2029).
link: https://www.vatupdate.com/2026/09/26/russia-proposes-22-vat-on-cross-border-online-purchases/
Deposit Interest Excluded From Simplified-Regime VAT Exemption Test
- Entrepreneurs may exclude Russian bank deposit interest when testing the RUB 20 million threshold for the 2026 exemption.
- Applies where total income including interest does not exceed RUB 60 million.
- The exemption ends if 2026 qualifying income exceeds RUB 20 million.
Clarifications on Reduced Rates Under the Simplified Tax Regime
- Russian tax authorities clarified the use of reduced VAT rates by simplified-regime taxpayers.
- Includes when the 0% rate may be applied by taxpayers using the 5% and 7% rates.
- Relevant for businesses under the simplified tax regime.
Serbia
Electronic VAT Records Extended to Farmer Purchases and Exports
- VAT-registered buyers must electronically record purchases from non-VAT-registered farmers, aggregated per VAT period, by the 12th of the following month.
- The e-invoicing system will also show export customs declaration data.
- Amendments apply generally from 1 January 2027; these provisions from 1 July 2027.
One-Year Ban for Invalid Fiscal Receipt QR Codes
- Serbia introduces a one-year ban linked to invalid fiscal receipt QR codes.
- Relevant for retailers issuing fiscal receipts.
- Concerns fiscalization compliance.
Slovakia
Proposal to Defer Buyer-Side Reporting to July 2030
- Draft LP/2026/282 would postpone customers’ reporting of received e-invoice data from 1 January 2027 to 1 July 2030.
- The obligation to receive Peppol-based e-invoices and supplier-side reporting would still apply from 1 January 2027.
- Businesses should continue inbound Peppol preparations.
Peppol BIS Validation Guidance Version 1.11 Published
- Version 1.11 addresses invoices with mixed VAT regimes, categories, exemption reasons, reverse charge and calculations.
- Relevant for businesses and providers building Slovak invoice mappings.
- Supports the 2027 e-invoicing framework based on Peppol BIS and EN 16931.
Third-Sector Organisations Receive Tax IDs Ahead of 2027 E-Invoicing
- Third-sector organisations are receiving tax identification numbers ahead of mandatory e-invoicing.
- Relevant for non-profit organisations.
- Linked to mandatory e-invoicing in 2027.
1,600 Firms Adopt Digital Mailbox as eFaktúra Preparations Continue
- The Financial Administration is helping businesses prepare for e-invoicing; 1,600 firms have adopted the digital mailbox.
- Relevant for Slovak businesses preparing for e-invoicing.
- Published 24 September 2026.
Device Fiscalization Procedure and VAT Registration Certificate Requests
- VATupdate published procedural guidance on device fiscalization in Slovakia.
- A separate post covers the procedure for requesting a VAT registration certificate.
- Relevant for retailers and VAT-registered businesses.
link: https://www.vatupdate.com/2026/09/26/procedure-for-requesting-a-vat-registration-certificate/
Slovenia
EU VAT Refund Claims Due 30 September via eDavki
- Slovenian VAT-registered taxpayers must file claims for VAT charged in other Member States in the previous year by 30 September.
- Claims are filed via eDavki and forwarded to the Member State of refund.
- Refund conditions differ by Member State.
Amendments to the Value Added Tax Act
- Slovenia has amendments to its Value Added Tax Act.
- Relevant for businesses with Slovenian VAT obligations.
- Published 25 September 2026.
Spain
Tax Agency Details Public B2B E-Invoicing Platform (SPFE)
- A hybrid model combines private platforms with a public solution using UBL 2.5 aligned with EN 16931 and lifecycle status reporting.
- Peppol BIS 3.0 users may need data transformation.
- Possible start dates: 1 October 2027 (turnover above EUR 8 million) and 1 October 2028, subject to the Ministerial Order.
Verifactu and B2B E-Invoicing: Two Separate Obligations
- Verifactu targets invoicing fraud through unalterable records; B2B e-invoicing aims to reduce late payments.
- PDFs will not be valid for B2B e-invoicing; status reporting is required.
- Verifactu: January 2027 (companies), July 2027 (self-employed); B2B dates depend on the Ministerial Order.
Form 361: VAT Refunds for Non-EU Businesses
- Form 361 is used by businesses established outside the EU to recover VAT incurred in mainland Spain and the Balearics.
- Refunds depend on Article 119 bis conditions, including reciprocity and, where required, a Spanish representative.
- It does not cover Canary Islands IGIC or Ceuta/Melilla IPSI.
DGT: One-Time Adjustment for Aparthotel Change Before Operation
- The DGT addressed a one-time VAT adjustment where an aparthotel’s intended use changed before operation began.
- Relevant for real estate developers and hotel operators.
- Published 24 September 2026.
Free Employee Car Use Not Subject to VAT Despite Partial Deduction
- Free use of a company car by employees is not subject to VAT despite partial input VAT deduction.
- Relevant for employers providing company cars.
- Published 25 September 2026.
Sweden
Tax Agency: VAT on Company Cars Provided Against Salary Deductions
- Employers must charge VAT where employees receive company cars in exchange for net or gross salary deductions.
- VAT may be calculated on the deduction amount for broadly offered staff benefits; arrangements limited to executives may be challenged.
- Whether input VAT restrictions on passenger cars still apply remains unresolved.
Switzerland
Federal Supreme Court: No Option or Deduction Before Tax Liability
- The option for a real estate supply cannot be exercised if the supply occurs before VAT liability begins.
- The land register transfer (24 November 2015) preceded registration (1 January 2016); the sale was exempt and deduction denied.
- VAT shown on the invoice was assessable under Article 27 VAT Act.
Company Holiday Homes: Inconsistent VAT Case Law
- Case law on company-owned holiday homes used by shareholders has produced three different outcomes.
- Where structures mainly generate input VAT advantages, tax avoidance may be found.
- A company solely providing the property to its shareholder carries on no entrepreneurial activity.
Solar Self-Consumption Communities: Landlord as Electricity Supplier
- In a ZEV between landlord and tenants, the landlord is treated as the electricity supplier for VAT.
- Tenants receive electricity bills from the landlord; the ZEV has no separate VAT status.
- Based on the Energy Act effective 1 January 2018.
VAT Liability Looms for Digital Service Platforms
- Digital service platforms face upcoming Swiss VAT liability.
- Relevant for platform operators facilitating supplies in Switzerland.
- Published 26 September 2026.
VAT Tax Liability: Handling Cross-Year Revenues
- The article addresses how revenues spanning two years affect VAT liability.
- Relevant for Swiss businesses assessing VAT liability.
- Published 25 September 2026.
Turkey
Scrap and Waste Trade VAT Rules Explained
- The article explains Turkish VAT rules for trade in scrap and waste.
- Relevant for scrap and waste traders.
- Published 25 September 2026.
VAT Withholding Non-Payment and Joint Liability
- The article addresses joint liability where withheld VAT is not paid.
- Relevant for buyers applying VAT withholding.
- Published 26 September 2026.
Ukraine
Alternative Bill 16037-1 Proposes VAT Administration Simplifications
- Raises the threshold for unscheduled refund audits from UAH 100,000 to UAH 1 million.
- VAT-registered sole proprietors could choose monthly or quarterly reporting.
- Pre-filled returns and consolidated month-end invoices for non-VAT payers are proposed.
Proposed VAT Increase to 21% to Fund First-Loss Compensation
- The Economy Ministry is consulting on a fund of up to $10 million financed by raising VAT from 20% to 21%.
- Small business representatives oppose; some associations support.
- The Finance Ministry describes it as an extraordinary food-security measure.
VAT Return Forms to Be Simplified
- The State Tax Service drafted new VAT return forms with fewer lines and grouped indicators.
- Annex D1 Table 1.2 would capture all liability adjustments; D5 Table 2 would be removed.
- Procedure No. 21 would be aligned.
Common SAF-T UA Technical Errors Published
- The State Tax Service published common errors from automated SAF-T UA checks.
- Covers key/keyref validation and logical consistency checks, with causes and remedies.
- Intended to help taxpayers correct files earlier.
Receipt Date Governs Deadline for Negative Adjustment Notes
- Deadlines for negative adjustment notes run from buyer receipt: 15 days, or 18 during martial law.
- The tax service recommends SWinED records as proof.
- The Supreme Court takes a more taxpayer-friendly approach.
Compensation for Damaged or Lost Property Outside VAT Base
- Compensation for damaged, destroyed or lost property is not included in the VAT base.
- VAT applies to supplies, not damages compensation.
- Compensation may be in cash or in kind.
New Invoice Required for Price Increases After 1,095 Days
- A correction to an old invoice cannot be registered after 1,095 days.
- The supplier must issue a new VAT invoice for the increase.
- Relevant for suppliers adjusting consideration long after supply.
Possible VAT Registration for Sole Proprietors Under EU Rules
- Ukraine may require VAT registration for sole proprietors in line with EU rules.
- Relevant for sole proprietors (FOPs).
- Status: under consideration.
Converting Sole Proprietorship to LLC: Preserving VAT Status
- The article covers VAT status and re-registration when transforming a private entrepreneurship into an LLC in 2026.
- Relevant for entrepreneurs restructuring their business.
- Published 24 September 2026.
War-Damaged Housing: When VAT Exemption Applies to Repairs
- The article addresses when VAT exemption applies to repair and reconstruction of war-damaged housing.
- Relevant for contractors and property owners.
- Published 25 September 2026.
United Kingdom
HMRC VAT Assist: Pre-Filing Checks on Draft VAT Returns
- VAT Assist will compare draft return data with HMRC-held information via MTD software and send rule-based warnings.
- Warnings will not block submission; it is not a pre-filled return or CTC system.
- Planned from around April 2027; API in alpha; industry consultation expected early October 2026.
link: https://www.vatupdate.com/2026/09/24/hmrc-vat-assist-enters-alpha-testing-for-draft-return-feedback/
link: https://www.vatupdate.com/2026/09/24/hmrc-vat-assist-to-check-draft-vat-returns-before-filing/
FTT: Collagen Beauty Drinks Standard-Rated, Not Zero-Rated Food
- In Minerva Research Labs v HMRC, collagen drinks were held to be liquid beauty products, not food.
- A multifactorial test considered ingredients, appearance, marketing and function.
- HMRC’s refusal to refund about £3.64 million was upheld.
FTT: Hypercar Input VAT Recoverable for Hire Business
- In Luxurico Ltd v HMRC [2026] UKFTT 1252, the car input tax block did not apply.
- The taxpayer proved an objective intention at acquisition to use the car mainly for qualifying hire.
- Contemporaneous evidence of intended hire use is critical.
link: https://www.vatupdate.com/2026/09/24/luxurico-vat-claim-on-hypercar-hire-upheld-by-ftt/
FTT: Outsourced Payroll Is Not a Supply of Staff
- Payroll companies supplied payroll administration, not staff, to ITS Plant-Tech Ltd, which remained the real employer.
- VAT charged on wages and employer NICs was not recoverable.
- Operating PAYE does not by itself make a payroll company the employer.
HMRC GfC20 on Outsourced Fund Management Services
- GfC20 sets HMRC’s approach to single versus multiple supply analysis for outsourced fund management.
- For exemption, services must be distinct, specific and essential to managing a qualifying fund.
- The guidance does not change the law.
HMRC Changes Overseas Refund Rules for VAT Group Members
- Each eligible non-UK group member must claim separately for UK VAT it incurred.
- For 1 July 2025–30 June 2026, either the member or representative member may claim, by 31 December 2026.
- Refused claims since 2021 may be reconsidered on request by 31 August 2027.
Education by Non-Eligible Bodies: HMRC Brief and Protective Claims
- The Court of Appeal in St Patrick’s International College held some education by non-eligible bodies can be exempt.
- HMRC maintains its position and has permission to appeal to the Supreme Court.
- Alternative providers may file protective claims.
Upper Tribunal Upholds Best-Judgment Assessment on Restaurant
- HMRC’s assessment using merchant-acquirer data, a deliberate penalty and a director liability notice were upheld.
- An assessment need only be a genuine, reasoned estimate.
- Fresh evidence was not admitted on appeal.
HMRC Updates List of Persons Connected With VAT Fraud
- HMRC updated its list of persons involved in transactions connected with VAT fraud to March 2026.
- Supports businesses’ due diligence and anti-fraud checks.
- Published 25 September 2026.
Upper Tribunal Upholds Fraud Knowledge Findings in Eurolaser
- The Upper Tribunal upheld findings on knowledge of VAT fraud in the Eurolaser case.
- Relevant for businesses in supply chains exposed to fraud risk.
- Published 25 September 2026.
Temporary Zero Rate for Domestic Electricity in Great Britain
- A temporary zero rate applies to domestic electricity in Great Britain.
- Relevant for electricity suppliers and domestic consumers.
- Temporary measure.
Overview of Main UK VAT Regulatory Developments
- VATupdate published an overview of the main UK VAT regulatory developments.
- Relevant for businesses with UK VAT obligations.
- Published 26 September 2026.
Americas
Argentina
Opposition Proposal: Dual VAT and Electronic-Payment VAT Refunds
- The proposal would replace provincial Gross Income Tax with a dual national and subnational VAT.
- Micro-SMEs would pay a fixed turnover tax; VAT refunds would apply to electronic-payment purchases, initially food.
- It includes an Argentine version of Brazil’s PIX payment platform. Status: political proposal.
Canada
CRA Memorandum Clarifies GST/HST Province-of-Supply Rules for Services
- Where several recipient addresses exist, the contracting address is generally the most closely connected.
- The rule for services in relation to tangible personal property does not apply where the connection is only indirect.
- Where no address is obtained, CRA looks at where relevant activities are performed.
Court Decisions on New-Home GST/HST Rebates and Assessments
- An Ontario new housing rebate appeal was dismissed.
- In Shameti v The King, a GST/HST self-supply assessment was appealed; a separate assessment was upheld on an alternate basis for new-home HST liability.
- Relevant for builders and purchasers of new homes.
link: https://www.vatupdate.com/2026/09/24/shameti-v-the-king-gst-hst-self-supply-assessment-appeal/
Chile
Proposed Place-of-Supply Changes for Financial and Wealth Management
- Chile proposes amending VAT place-of-supply rules for financial management, advisory and consulting services.
- Wealth management services are also targeted.
- Part of a broader package of tax measures under consideration.
Dominican Republic
ITBIS Withholding Exempted Between Authorised E-Invoice Issuers
- The DGII exempts certain ITBIS (VAT) withholdings on e-CF transactions between authorised electronic issuers.
- Affects businesses authorised to issue electronic tax receipts.
- Clarifies ITBIS withholding rules for e-invoice payments.
- link: https://www.vatupdate.com/2026/09/22/dgii-exempts-vat-withholdings-on-e-cf-transactions-between-authorized-electronic-issuers/
- link: https://www.vatupdate.com/2026/09/22/dominican-republic-exempts-authorized-e-invoice-issuers-from-certain-itbis-withholding-obligations/
- link: https://www.vatupdate.com/2026/09/22/dominican-republic-exempts-itbis-withholding-on-e-invoice-payments/
Mexico
List of VAT-Registered Non-Resident Digital Service Providers Published
- Mexico has published the list of non-resident digital service providers registered for VAT.
- Relevant for Mexican customers and platforms dealing with foreign digital providers.
- Published 24 September 2026.
Uruguay
E-Invoicing Test Certificate Updated
- Uruguay has updated the e-invoicing test certificate for RUT 219999830019.
- Relevant for e-invoicing software providers and issuers testing integrations.
- Technical update.
Asia-Pacific
Bangladesh
Online VAT Returns Mandatory for 11 Major Sectors
- Under amended Section 64, online filing becomes mandatory for sectors including cigarettes, mobile phones, medicines, cement, banks, insurers and mobile financial services.
- Prior orders on mandatory online filing will be invalidated.
- Via an upcoming gazette; expansion to all VAT payers is planned.
link: https://www.vatupdate.com/2026/09/21/nbr-makes-online-vat-return-mandatory-in-11-sectors/
Cambodia
Prakas 584 on Business Transfers; Dental Services Exempt
- Prakas No. 584 clarifies tax liability allocation and VAT treatment for business transfers, share transfers and mergers.
- Instruction No. 14 reaffirms that dentistry services are not subject to VAT.
- Relevant for parties to restructurings and dental providers.
China
Business Buyers to Withhold VAT on Services From Individuals
- Business customers must withhold VAT and surtaxes when paying domestic individuals for R&D, software, design, consulting, cultural and education services.
- Remittance within 15 days from the start of the following month; thresholds apply; platform-based supplies are excluded.
- Applies from 1 November 2026.
New VAT Administrative Rules on Deduction and Withholding
- Notice No. 25 uses positive and negative lists for input VAT on non-taxable transactions.
- Notice No. 28 introduces withholding by enterprises on transactions with natural persons.
- A pilot VAT and surtax return applies in Hebei, Jiangsu, Hubei, Shaanxi and Shanghai.
India
Excess IGST Export Refund Not Deniable for Clerical Error
- A refund of excess IGST paid on exports cannot be denied merely because of a clerical error in GSTR-3B.
- Relevant for exporters claiming IGST refunds.
- Judicial decision.
Works Contract to Statutory Authority Not Eligible for Concession
- A works contract for a statutory authority is not eligible for the local authority GST concession.
- Relevant for contractors serving public-sector bodies.
- Published 22 September 2026.
Industry Seeks Use of ITC to Pay Reverse Charge Liability
- Industry urges the GST Council to allow RCM liability to be paid with input tax credit instead of cash.
- Cash payment is said to block working capital, notably in FMCG, pharma, footwear and automobiles.
- Status: industry request.
Indonesia
SPP-TDLN Launched for VAT on Cross-Border Digital Transactions
- Indonesia has launched SPP-TDLN for VAT on cross-border digital transactions.
- Relevant for foreign digital service providers.
- Published 25 September 2026.
Japan
Cabinet Outline: Temporary 1% Consumption Tax on Food
- Qualifying food and beverages would move from 8% to 1%; restaurant services remain at 10%.
- Flexibility is proposed for exempt and simplified-taxation businesses.
- Proposed period 1 April 2027 to 31 March 2029; a bill must still go to the Diet.
Kyrgyzstan
Foreign Digital Service Providers Must Register Before Starting
- Foreign providers of electronic services to Kyrgyz residents must register before commencing activity.
- Portal registration also constitutes VAT registration; this does not create a permanent establishment.
- Covers software, games, advertising, hosting, data storage and digital content.
Maldives
GST Registration and Returns for Overseas Tourism Suppliers
- Overseas suppliers of inbound tourism products register via MIRA 120 and file MIRA 211; the 17% rate applies.
- Affects foreign tour operators, OTAs, bed banks and booking platforms.
- Applies from 1 October 2026; electronic filing for all registered persons from 1 January 2027.
New Zealand
Court: Third-Party Insurance Payment Subject to GST
- A New Zealand court ruled that a third-party insurance payment is subject to GST.
- Relevant for businesses receiving payments from insurers.
- Judicial decision.
Pakistan
SRB Holds Fourth POS Invoice Prize Draw
- Sindh Revenue Board awarded 95 prizes from 217,525 verified POS invoices.
- Retail services including restaurants, beauty parlours and gyms must integrate POS systems for real-time reporting.
- The scheme aims to encourage demand for verifiable invoices.
Sales Tax Return Deadline for August 2026 Extended
- Pakistan has extended the sales tax and federal excise return filing date for August 2026.
- Relevant for registered sales taxpayers.
- Applies to the August 2026 period.
Philippines
Update: RMC 98-2026 Confirms E-Invoicing Compliance by 31 December 2026
- Covers e-commerce businesses, large taxpayers and users of computerised accounting or invoicing software; micro taxpayers are excluded.
- A Permit to Issue is required; PDFs or Word/Excel invoices do not qualify.
- Electronic sales reporting follows separately.
link: https://www.vatupdate.com/2026/09/25/bir-allows-firms-to-build-or-buy-e-invoicing-systems/
RMC 97-2026: Allowable System Loss Charge Excluded From VAT
- The allowable system loss charge within the ERC cap is a pass-through cost, not income.
- It is excluded from generation companies’ VAT base.
- Losses above the cap are not covered.
Taiwan
Warning on Duplicate E-Invoice Numbers and Prize Reimbursements
- Taiwan warns businesses about duplicate e-invoice numbers and prize reimbursements.
- Relevant for businesses issuing eGUI invoices.
- Published 25 September 2026.
Uzbekistan
Non-Resident VAT Regime Extended to Online Goods Sellers
- Foreign entities selling goods B2C via electronic platforms fall within the non-resident VAT regime.
- Platforms settling payments may act as tax agents; B2B buyers self-assess.
- Effective 12 December 2026.
Vietnam
Circular on Electronic VAT Refunds for Departing Foreigners
- An electronic VAT refund management system is created for goods bought by foreigners and overseas Vietnamese on exit.
- Sets procedures for participating retailers, banks acting as refund agents, airports and seaports.
- Assigns responsibilities to customs, tax authorities, banks and sellers.
10% VAT on Additional AI Chatbot Message Fees
- Additional per-message fees for an AI chatbot platform are subject to 10% VAT if not within exempt or 5% categories under Decree 181/2025.
- Whether the fee is bundled depends on the company’s sales policy.
- Relevant for digital service providers.
Middle East
Bahrain
Margin Scheme Limited to Used Goods Previously Subject to VAT
- Goods acquired before 1 January 2019, or not previously subject to VAT, are excluded; VAT applies to full price.
- Dealers must retain evidence such as invoices, customs declarations or first-registration dates.
- Published 20 September 2026 in the updated Retail and Wholesale Guide (v1.3) and General Guide.
link: https://www.vatupdate.com/2026/09/24/bahrain-updates-vat-general-and-retail-wholesale-guides/
Qatar
Qatar Considers VAT to Ease Budget Pressures
- Qatar is considering introducing VAT amid revenue shortfalls.
- Relevant for businesses operating in Qatar.
- Status: under consideration.
United Arab Emirates
Cabinet Decision 149 of 2026 Overhauls VAT Executive Regulations
- Amended regulations apply from 1 October 2026; residual recovery moves to an output-based method from 1 October 2027.
- Input VAT will be denied for cash payments above a threshold yet to be set.
- Employee-expense recovery is tightened; composite supply rules are updated.
link: https://www.vatupdate.com/2026/09/21/uae-amends-vat-executive-regulations-2/
FTA Clarification VATP046 on E-Invoicing Amendments
- Defines Electronic Invoicing System, Electronic Invoice and Electronic Credit Note.
- Once applicable, invoices must be issued, transmitted and retained electronically to support recovery.
- Also covers the non-resident definition, reverse charge and tax-evasion-linked input tax.
E-Invoicing From 1 January 2027 for Large Taxpayers
- Five-corner DCTCE model; structured XML under Peppol PINT-AE; PDFs and scans are not used.
- Covers B2B and B2G, regardless of VAT registration; B2C is excluded.
- Starts 1 January 2027 for large taxpayers.
PDF Is Not E-Invoicing: Guidance for UAE Finance Leaders
- The article explains that a PDF does not constitute an e-invoice under the UAE system.
- Aimed at UAE finance leaders.
- Published 22 September 2026.
VAT for Multi-Branch Retail in Dubai: POS Controls
- The article covers VAT for multi-branch retailers in Dubai, including POS controls and tax filing.
- Relevant for retailers operating several branches.
- Published 25 September 2026.
Africa
Botswana
Guidance on Reverse-Charge VAT Reporting Under VAT Act 2026
- Covers when reverse-charge-liable persons must prepare recipient-created invoices.
- Registered recipients of remote services must notify non-residents of their registration.
- Follows the VAT Act 2026, effective 1 July.
Ghana
GRA Targets VAT Gap Reduction From 60% to 30% by 2028
- The VAT Strategic Plan aims to cut the VAT gap to about 30% by end-2028.
- A campaign found businesses not consistently issuing VAT invoices.
- Education first; deliberate non-compliance will be enforced.
link: https://www.vatupdate.com/2026/09/25/gra-launches-national-vat-awareness-and-compliance-campaign/
Ivory Coast
45 Days to Align E-Invoicing API Interfaces With FNE
- Businesses using API-based e-invoicing and accredited integrators must align with FNE specifications.
- Non-compliance may lead to API key suspension plus penalties.
- The 45-day period runs from 14 September 2026.
Kenya
KRA Outlines VAT Changes Under Finance Act 2026
- Bad-debt refund claims now after 3 years (was 2); input tax on stock must be reversed when supplies become exempt.
- Digital payment service fees and commissions are standard-rated.
- Returning passengers’ VAT-free allowance rises from USD 300 to USD 2,000.
Morocco
Meta to Add 20% VAT on Some Moroccan Ad Purchases
- Meta will add 20% VAT on some advertising purchases in Morocco.
- Relevant for Moroccan advertisers buying ads on Meta platforms.
- Applies from 1 October 2026.
Namibia
E-Invoicing in Namibia: Status and Timeline
- The article sets out the current status and timeline of e-invoicing in Namibia.
- Relevant for businesses operating in Namibia.
- Published 25 September 2026.
South Africa
SARS Consults on Digital VAT Model With E-Invoicing
- The model moves from declarations to structured e-invoicing, interoperability, e-reporting and eventually auto-assessments.
- An e-invoice must be structured and machine-readable, not a PDF or scan.
- Businesses will likely need system upgrades; FAQs and guidance were also issued.
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