Global VAT & Indirect Tax News

The Philippine Court of Tax Appeals issued a decision (CTA EB No. 2951) on Jan. 16, 2026 clarifying the treatment of unutilized input VAT refunds on zero‑rated export sales. The court partially granted a refund claim by a corporation engaged in export sales, after the Commissioner of Internal Revenue denied the request for lack of proof that service recipients were not doing business in the Philippines.

The European General Court dismissed an Italian association’s challenge to EU VAT directives that impose a deemed‑supplier model on digital platforms for short‑term accommodation rentals. The court held the association lacked direct and individual concern, as the rules target platform operators, not property owners. The decision confirms the applicability of Directive (EU) 2025/516 and Regulation (EU) 2025/518.

The blog outlines emerging trends in intra‑group loan transfer pricing for 2026, highlighting recent court rulings in Luxembourg, Belgium, and the Netherlands that tighten documentation and credit‑rating requirements. It stresses the need for fact‑specific debt‑capacity analyses, robust credit‑rating methodologies, and clear contractual terms to mitigate audit risk. Multinationals should align loan terms with arm‑s‑length principles and document them comprehensively.

The Bombay High Court ruled that a minimum three‑month gap must exist between a Section 73(2) show‑cause notice and the final order under Section 73(10) in GST proceedings. Orders passed earlier, such as the two‑and‑a‑half‑month order in the A.M. Marketplaces case, were quashed. The decision underscores procedural fairness and the need for adequate time for taxpayers to respond.

Brazil’s new dividend withholding tax (WHT) has been in force for nearly a month, but questions remain about its application. The December 16, 2025 Q&A confirms that dividends paid to foreign governments, sovereign funds and social‑security‑benefit managers are exempt, and that the exemption also covers entities wholly owned by exempt investors. However, in structures where a Brazilian entity is held by a foreign holding company only partially owned by exempt investors, the exemption may not apply, potentially subjecting dividends to full WHT.

Circular 807-1, issued in October 2025, removed the ability for Luxembourg resident employees in taxable rental car policies to reduce the taxable base for business mileage, potentially increasing VAT costs for those with significant professional travel. The change also raises operational questions about the backdating of adjustments and filing corrections, and highlights challenges for cross‑border employees. Companies may need to rethink their car policies in light of these developments.

The article introduces a robot that automates the validation of EU VAT numbers via the VIES API, reducing manual effort and errors. It outlines a four‑step process that extracts VAT numbers from any file format, checks them against the VIES database, generates a PDF and Excel report, and emails the results. The service promises faster, 100% accurate validation and frees users to focus on higher‑value tasks.

The OECD has renewed its call for Australia to broaden and potentially raise the GST to improve fiscal sustainability. It recommends expanding the tax base and considering a rate increase above the current 10%, possibly up to 15% if paired with income‑tax cuts, and estimates a 1.6% boost to output over ten years. The recommendation comes ahead of the May federal budget and follows a mid‑year budget update that confirmed persistent deficits.

On 21 January 2026 the Philippine Court of Tax Appeals issued CTA Case No. 10505, clarifying that unutilized input VAT refunds on zero‑rated sales must be substantiated with an administrative refund claim and proof of entitlement. The decision confirms that the Internal Revenue Commissioner’s denial of a 2018 excess input VAT refund was based on the taxpayer’s failure to meet these requirements.

The UK Supreme Court confirmed that VAT incurred on adviser fees related to an exempt share sale is not recoverable, applying a strict two‑stage test that requires a direct and immediate link to the transaction. The ruling rejects the modified approach that allowed recovery based on intended use of proceeds and clarifies that VAT grouping does not alter the nature of a share sale. Businesses must conduct early VAT analysis for share disposals to account for irrecoverable adviser fees.

Moldova’s legislature has amended the Tax Code to raise the VAT registration threshold to 3.2 million lei, a move that the Ministry of Finance only partially supports by proposing 1.7 million lei. The current threshold, effective 1 January 2026, stands at 1.5 million lei, and the EU directive caps the limit at 85 000 € or its equivalent.

On 26 January 2026, the UK Supreme Court ruled that VAT incurred on adviser fees for an exempt share sale is not recoverable. The decision applies a strict two‑stage test, rejecting the modified approach that allowed recovery based on intended use of proceeds. The ruling closes the possibility of treating such costs as general overheads to fund taxable activities.

The Ghana Revenue Authority has raised the VAT registration threshold from GH¢200,000 to GH¢750,000 per annum, effective 26 January 2026. Businesses below the new threshold will be deregistered and placed under the Modified Tax Scheme, which offers simplified compliance options. The move aims to reduce the compliance burden on micro and small businesses in the informal sector.

The article discusses the completion of GST 2.0 in India, the removal of the GST compensation cess, and the introduction of new excise rates on demerit goods such as cigarettes. It highlights how the excise notification could trigger a tax shock, affecting tobacco growers, small retailers, and the broader economy. Monthly GST collections in late 2025 remained robust, exceeding Rs 1.7–1.9 lakh crore.

The article discusses recent Supreme Court rulings and a BIR circular that simplify VAT zero‑rating and refund procedures for renewable energy developers in the Philippines. It explains that developers no longer need a DOE COE or an ERC COC, and that local suppliers no longer must file zero‑rating applications. The piece also outlines the conditions under which input VAT can be refunded and advises developers to maintain proper registration certificates.

The Philippine Court of Tax Appeals issued a decision on Jan. 19, 2026 (Case No. 10607) clarifying the validity of assessments for alleged tax deficiencies. The ruling covers a range of taxes—including income tax, VAT, expanded withholding tax, and others—and finds that due process was not violated because the Final Decision on the Disputed Assessment (FDDA) stated the relevant facts. The decision provides guidance on how assessments are evaluated for due process compliance.

France will transfer all VAT provisions from the General Tax Code into a new consolidated framework, the Code de l’imposition sur les biens et services (CIBS), effective 1 September 2026. The reform modernises the legislative structure, codifies EU measures such as the ViDA package and IOSS, and allows a transition period until 31 December 2027. E‑invoicing rules remain outside the CIBS for the time being.

The Federation of Bosnia and Herzegovina’s House of Representatives adopted a draft law on fiscalization of transactions, establishing obligations for electronic invoicing, a real‑time transaction recording system, monitoring mechanisms, and criminal provisions to curb tax evasion. The law builds on the 2009 fiscal systems law and aims to modernize tax compliance across the Federation.