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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.
Global e-Invoicing Requirements Tracker
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.
Chile’s Internal Revenue Service (SII) has issued new resolutions in 2025 that expand electronic invoicing obligations. The updates require digital platform operators to verify seller registrations, mandate electronic receipts for all in‑person sales, and introduce a Delivery Note Registry with detailed transport information. Electronic invoicing has been mandatory since February 1 2018, and the SII continues to enforce validation and acceptance timelines.
The German Ministry of Finance clarified rules on input VAT deductions for subsidized service providers that operate at persistent loss. The BMF Letter states that such providers cannot deduct input VAT for services unrelated to taxable activity and must satisfy a two‑step test linking remuneration to performance and confirming economic activity. The letter also amends the VAT Application Decree.
Poland’s Ministry of Finance and Economy has signed four executive regulations that finalize the technical and organisational aspects of the National E‑Invoicing System (KSeF). The new rules set exemptions for certain services, change simplified invoice handling, and introduce mandatory JPK_VAT reporting with KSeF identifiers from 1 February 2026. Businesses must update their accounting and ERP systems to comply with the new authorisation, authentication and data‑scope requirements.
The article explains how withholding VAT regimes are used in Mexico and Argentina to collect VAT on digital services supplied by non‑resident providers. It details the rates and responsibilities of platforms, intermediaries, and customers, and notes that withholding can sometimes replace registration for foreign suppliers.
The Philippine Court of Tax Appeals issued a decision on Jan. 16, 2026 in CTA Case No. 10570, ruling that yearbook printing is VAT‑exempt because yearbooks qualify as books under Philippine law. The ruling invalidated the Commissioner of Internal Revenue’s assessments for deficiency income tax and VAT for the taxable year 2013, which had been based on BIR Ruling No. 421‑2013. The decision clarifies the validity of such assessments and the treatment of yearbook sales for VAT purposes.
The Federation of Bosnia and Herzegovina has approved a bill that would make B2B and B2G e-invoicing mandatory via a Central Platform for Fiscalisation (CPF) and require B2C transactions to use approved Electronic Fiscal Systems (EFS). The proposal aims to align with the EU ViDA model by July 2030 and has moved from the Lower House to the upper house for final approval.
Zimbabwe’s tax authority has clarified that non‑resident digital service providers must remain VAT‑registered if their annual turnover from services consumed in Zimbabwe exceeds USD 25,000, even after the introduction of Digital Services Withholding Tax (DSWT). The DSWT withholding amount is credited against the supplier’s VAT liability, but all compliance obligations, including fiscalisation, continue to apply. The fiscalisation mandate has been live for all VAT‑registered taxpayers since June 2025.
A non‑binding opinion from an EU Court of Justice adviser clarifies that Stellantis Portugal SA’s practice of adjusting sales prices for dealerships does not constitute a service and therefore is not subject to VAT. The opinion adds to a growing body of guidance on VAT treatment of transfer‑pricing adjustments and highlights the European Commission’s focus on closing the €128 billion VAT gap reported in 2023.
HMRC has reset UK VAT grouping rules, allowing overseas establishments to be treated as part of a UK VAT group and removing EU case law such as Skandia and Danske Bank. The new policy reduces cross‑border VAT friction and invites businesses to correct over‑declared VAT, while expanding HMRC’s discretion to deny grouping where it sees collection risk or distortive outcomes.