Global VAT & Indirect Tax News

The Advocate General’s opinion in the Stellantis Portugal case (C‑603/24) clarifies that transfer pricing adjustments between group companies are to be treated as adjustments to the original prices of earlier sales, not as separate repair services. Consequently, corrective invoices must be issued and the VAT taxable base of those earlier supplies must be adjusted. The final CJEU judgment is expected later in 2026.

The European Commission’s ViDA initiative introduces a common EU digital reporting standard, mandatory e‑invoicing for intra‑EU B2B transactions, and expands the OSS/IOSS to cover more B2C supplies. It also imposes platform‑operator deemed‑supplier rules for accommodation and transport services. The phased rollout runs from 2025 to 2035, requiring businesses to modernise their tax technology and processes.

The Advocate‑General has clarified that transfer‑pricing (TP) adjustments made for direct tax purposes do not attract VAT, but TP adjustments that are contractually agreed within intra‑group supplies of goods are within the scope of VAT. In the Stellantis Portugal case (C‑603/24), the Portuguese tax authorities imposed VAT assessments on Stellantis Portugal for TP adjustments, and the Advocate‑General advised the European Court that such adjustments should be treated as price adjustments for vehicles. Businesses are urged to review their TP policies and implement VAT considerations in their ERP systems.

The ViDA package represents a sweeping overhaul of the EU VAT system, aiming to curb fraud, simplify SME compliance, and create a fairer digital marketplace. It introduces mandatory e‑invoicing and near real‑time digital reporting for intra‑EU transactions, expands the Single VAT Registration and Import One‑Stop Shop, and projects up to €18 billion in annual revenue gains and €5.1 billion in compliance cost reductions by 2030.

Sri Lanka has launched a national electronic invoicing framework to modernize its tax administration and curb tax evasion. The system, integrated with the existing Revenue Administration Management Information System (RAMIS) via a secure Web API, will roll out in stages, starting with a pilot phase expected to be fully deployed by the end of 2025 and eventually becoming mandatory for all VAT‑registered businesses and B2C POS transactions.

Austria will permanently cut the VAT on basic food items from 10% to 5% effective mid‑2026, a 50% reduction that the Austrian National Bank estimates will lower inflation by 0.5 percentage points one‑off. The move, welcomed by the Austrian Retail Association, is intended to provide lasting relief to consumers and is expected to be passed on by retailers where possible.

From 1 January 2026, Mauritius will impose VAT on digital and electronic services supplied by non-resident providers. Foreign suppliers must register for VAT regardless of turnover, and those exceeding MUR 3 million must appoint a tax representative. The new rules also eliminate the reverse charge for VAT‑registered foreign suppliers, requiring them to charge VAT on supplies to Mauritian businesses.

Cyprus has extended deadlines for VAT, VIES, and the Special Taxi Scheme to 20 January 2026, allowing submissions and payments without penalties. Businesses must be aware of the new penalties that will apply after this date. The extension covers VAT returns for the period ending 30 November 2025, VIES returns for December 2025, and the flat‑rate scheme for urban taxis from 1 July to 31 December 2025.

The article explains the conditions under which a B2B intra‑community supply of goods can be zero‑rated in the EU. It outlines the required documentation, reporting obligations, and the consequences of non‑compliance.

On 16 January 2026, the Nigeria Revenue Service clarified that VAT on banking services has always applied to fees, commissions and service charges, not to the money transferred. The NRS confirmed that the Nigeria Tax Act does not impose new tax obligations on bank customers and urged stakeholders to rely on official channels for accurate information.

HM Revenue & Customs has reversed its stance on UK VAT grouping, stating that EU case law restrictions no longer apply. The change allows overseas establishments of VAT‑grouped businesses to be treated as part of the group even in EU states that do not use whole‑entity VAT grouping, and invites firms to reclaim overpaid VAT. The policy, announced after the 2025 Budget, seeks to simplify cross‑border compliance and attract foreign investment.

Poland will require taxpayers to notify the e‑Tax Office before issuing invoices with attachments in KSeF 2.0 from 1 January 2026. The notification must include taxpayer details, activity type and technical parameters, and attachments must be part of the XML file. Additional legislative updates include simplified invoice rules, JPK_VAT amendments, and exemption provisions effective February 2026.

Mexico’s tax authority, SAT, has issued Rule 2.9.21 under RMF 2026, mandating digital platforms to provide real‑time, permanent online access to transaction records. The rule requires next‑day data availability, a five‑year searchable archive, and a formal request by April 30 2026, with detailed data obligations for both service providers and intermediary platforms.

The newsletter covers recent VAT developments, including a new EU customs duty for low-value parcels, a UK Supreme Court ruling affecting VAT recovery on fundraising activities, and a change in VAT treatment for locum doctors following HMRC's decision not to appeal a tribunal ruling.

Portugal’s government has proposed a 6% VAT rate on construction and rehabilitation works for primary residences, targeting urban development projects initiated between September 2025 and December 2029. The measure applies to sales under €648,022 and rentals under €2,300/month, with specific timing and lease conditions, and includes amended reverse‑charge rules and potential VAT refunds for individuals.

BDO’s 2026 update lists a range of VAT and excise duty changes across 22 jurisdictions, including new GST regimes, rate adjustments, and registration threshold shifts. Key highlights include Bhutan’s 5% GST from 1 January 2026, Denmark’s 0% VAT on books, and Ghana’s VAT rate cut to 20% with a higher registration threshold. The article serves as a quick reference for tax professionals monitoring upcoming indirect tax reforms worldwide.

Austria will reduce the VAT on certain food items from 10% to 5% mid‑2026, a measure financed by a new tax on non‑recyclable plastics. The specific foodstuffs eligible for the discount are yet to be defined, and the competition authority will enforce the reduction and ensure retailers pass the benefit to consumers.

The European Court of Justice ruled that Croatian VAT authorities cannot deny intra‑Community supply exemptions solely because a trader has not supplied the specific evidence required under Article 45a of Implementing Regulation No 282/2011. The court requires a full assessment of all evidence to determine whether goods were dispatched or transported between Member States. Businesses can still claim the exemption if alternative evidence demonstrates transport between Croatia and Slovenia.

The VAT Refunds Manual is an HMRC internal guidance document outlining procedures for traders to claim VAT refunds. It covers eligibility, claim requirements, time limits, verification, handling of abusive or unjust enrichment claims, end‑customer refund claims, refusal procedures, appeals, and penalties.

China’s new Value‑Added Tax Law and its Implementing Regulations entered force on 1 January 2026, bringing significant changes to taxable transaction definitions, VAT rates, and taxpayer status thresholds. The law retains the 13 %, 9 %, and 6 % rates, introduces a 3 % levying rate for the simplified tax method, and adjusts the real‑estate VAT rate for individuals to 3 %. Enterprises exceeding RMB 5 million in annual taxable sales must switch to the general taxation method, and the definition of taxable services and intangible assets now focuses on consumption within China or domestic sellers.