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 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.

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.

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.