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The EU Parliament has reopened debate on the optional reverse charge mechanism, which is set to expire on 31 December 2026. While the tool has proven effective in curbing missing trader intra‑community fraud in high‑risk sectors, concerns remain about VAT distortions and the need for complementary digital reporting controls. The review signals that reverse charge will stay part of the anti‑fraud toolkit but will be increasingly paired with real‑time transaction monitoring under the ViDA framework.
The article analyzes the CJEU ruling in Titanium Ltd v. Finanzamt Österreich (C-931/19) and its implications for fixed establishment and reverse charge in cross‑border B2B services. It clarifies that a fixed establishment requires permanent human and technical resources, and that the reverse charge applies when such an establishment exists. It also notes that Article 47 lex specialis applies to services linked to immovable property, making VAT payable in the Member State where the property is located regardless of a fixed establishment.
Global e-Invoicing Requirements Tracker
The article examines the CJEU ruling on whether a subsidiary automatically constitutes a fixed establishment for VAT purposes. It explains that a subsidiary must satisfy substantive conditions under Article 11 of Implementing Regulation No 282/2011, and that a third‑country parent operating through a subsidiary in Poland does not automatically create a fixed establishment. The ruling also clarifies that EU‑Korea FTA restrictions on corporate forms do not affect the fixed establishment concept.
The post outlines Portugal’s VAT framework, highlighting the 23% domestic rate, the 0% international regime for services to non‑EU clients, and the reverse‑charge rule within the EU. It also discusses exempt sectors under Article 9, the 6% reduced rate for affordable housing, and the digitised 2026 recovery process for VAT credits.
EU Parliament has tabled more than 200 amendments to its draft report on a coherent tax framework for the financial sector, with VAT reform at the centre. The proposals aim to narrow the long‑standing VAT exemption for financial services, tax fee‑based B2B services, consolidate the Insurance Premium Tax into VAT, and modernise rules for neobanks, crypto and other digital financial services. A parliamentary vote is scheduled for 26 April 2026, with a vote expected in May and potential plenary adoption in June.
Sri Lanka has postponed the introduction of VAT on non‑resident digital services to 1 July 2026, from the originally planned 1 April. The amendment imposes an 18 % VAT on B2C digital and electronic services, aligning the country with over 120 other jurisdictions. Guidance on registration and compliance will be released in 2027, while local providers already pay 18 % VAT and B2B services are expected to be zero‑rated.
The European Commission will host a public workshop on 27 April 2026 to review the revision of Directive 2014/55/EU on e‑invoicing in public procurement. The event will outline potential policy measures, gather stakeholder feedback, and discuss the three policy options for the revision. The outcome will influence upcoming compliance requirements, including the ViDA reform that will mandate structured e‑invoicing for intra‑EU B2B transactions by July 2030.
The article examines how fully automated, AI‑run companies—termed zero‑person companies—challenge existing VAT rules. It explains that while such entities can perform all operational tasks, they still require a human link for legal accountability, and their place of establishment for VAT purposes is determined by where central administration effectively occurs, often defaulting to the registered office. The piece also discusses the low likelihood of fixed establishments arising solely from cloud infrastructure and outlines compliance implications for tax authorities.
The article explains that real‑time tax compliance involves continuous exchange and validation of transaction data with tax authorities, embedding tax processes into operational workflows. It identifies three main barriers—fragmented system landscapes, data that is not real‑time ready, and legacy operating models—and argues that local, country‑by‑country solutions will not scale. The author advocates for a unified data platform and a shift to viewing tax as part of digital infrastructure.