RSM Ireland’s Spring 2026 VAT newsletter highlights key updates from Irish Revenue, including a new e‑invoicing mandate for large corporates, a 9% VAT rate for qualifying apartment construction, and guidance on Relevant Contracts Tax and fraud prevention.

ICAEW’s Tax Faculty reminds businesses that the deadline for submitting a VAT return and paying any VAT due to HMRC is not extended even if it falls on a weekend or Bank Holiday. The general rule is one calendar month and 7 days after the end of the accounting period, with specific dates for each period in 2026/27. Paper returns and the annual accounting scheme have their own distinct deadlines.

The article examines a case where an Italian company offers a €5,000 discount to a German customer in exchange for advertising services, treating the discount as a VAT swap under Article 11 of DPR 633/1972. It discusses whether the discount should be applied as a reduction on the supply invoice or issued as a separate credit note, and explains the reverse charge mechanism in Italy.

A buyer-side framework for tax, compliance and IT leaders preparing for global e-invoicing mandates that now bring penalties from day one. The five sequential steps are: map the mandate landscape (countries, transaction types, deadlines, urgency tiers), understand the compliance model behind each country (post-audit, decentralised/Peppol, real-time reporting, centralised platform, clearance), define technical requirements starting with ERP integration, formats and data residency, match vendors to your specific requirements through structured scoring rather than manual shortlisting, and validate the shortlist through peer intelligence on country-and-model-specific implementations. The article emphasises matching vendor architectural strengths to your country mix rather than chasing 'global coverage' claims.

A new Swedish bill adopted on May 6 2026 empowers the Swedish Tax Agency to deny input VAT credits for significant excess amounts during audits. The change expands the agency’s authority to challenge VAT recoveries that exceed allowable limits, requiring businesses to review their input VAT claims for compliance.

Brazil has introduced a dual VAT model replacing PIS, COFINS, ICMS, and ISS with CBS and IBS. Nonresident sellers must register for CBS/IBS, issue electronic invoices, and comply with split payment rules from August 2026, with CBS fully operational at 8.8% from 2027 and full implementation by 2033.

Morocco is moving toward a mandatory electronic invoicing system in 2026, with a centralized CTC model that will validate invoices in real time via the DGI platform. The reform will roll out progressively, starting with B2B transactions for large companies and later expanding to SMEs and B2C. The UBL format will be the required structured data standard, and invoices must include an electronic signature before validation.

UAE businesses face a July 1, 2026 deadline to pick an accredited e‑invoicing service provider and prepare their systems for the mandatory rollout. From January 1, 2027, e‑invoicing will apply to firms with annual turnover above Dh 50 million, using a decentralised 5‑corner model for B2B and B2G transactions. Companies must review accounting systems, conduct gap analyses, upgrade infrastructure, and train staff to avoid operational disruption.

Brazil has published the regulations for its new Tax on Goods and Services (IBS) and Contribution on Goods and Services (CBS), marking the operational start of the indirect tax reform. The regulations provide operational rules and a shared framework, requiring integrated compliance. Penalties may apply from August 2026, giving taxpayers a compressed adjustment period.

EU finance ministers endorsed an amendment to Regulation (EU) No 904/2010 that will allow OLAF and EPPO to query Member State VAT systems, but the amendment restricts access to read‑only, case‑by‑case searches and bans bulk extraction or AI analysis. The measure is pending Parliament approval, likely in July 2026, and will be routed through VIES, CESOP and Eurofisc channels.

The European Commission’s proposed EU bill would require member states to share VAT data with anti‑fraud agencies, but Spain has raised objections over data access provisions and inconsistencies. The proposal, introduced in November, seeks to strengthen cooperation against VAT fraud, which the Commission estimates costs the EU €90 billion annually. Spain plans amendments ahead of the upcoming EU finance ministers meeting.

Greek authorities have postponed the second phase of the myDATA e-delivery reporting regime to October 2026, while outlining a phased rollout with key compliance dates. Companies with 2022 revenues above €200,000 and those in certain sectors must report from 1 December 2025, with further digital tracking and QR code scanning introduced on 1 October 2026. The system will become mandatory for public sector entities on 1 January 2026, and CN item coding will be implemented on 1 January 2027.

Brazil introduced a new federal CBS tax on digital services effective 1 January 2026, replacing PIS and Cofins. The consolidated rate of 26.5% (CBS 8.8% + IBS 17.7%) applies to non‑resident providers and marketplaces, which must register and comply with Nota Fiscal e‑invoicing. B2B customers can self‑account, while B2C transactions are subject to collection by the provider.

Greek tax authorities have introduced a new framework that will reassess fines issued from 19 April 2024, cutting penalties by up to 80% and setting a standard €100 fine for late or missing filings that do not create a tax liability. The reform also eliminates the €250/€500 penalties for low‑value withholding tax declarations and removes fines for cases where the additional tax payable is below €100.

Greek VAT update: The omnibus tax bill tabled on 1 May 2026 introduces immediate tightening of the reverse charge for construction services, reduces the VAT rate on electricity transmission services to 6 %, and retroactively lowers penalties for nil and credit VAT returns and late withholding filings back to April 2024. Volume‑based rebate clarifications also take effect immediately. All changes are expected to apply from publication in the Official Gazette, with updates reflected instantly in invoices, VAT returns and e‑invoicing.

Brazil has enacted Decree No. 12,955, establishing a federal Contribution on Goods and Services (CBS) for digital services. The decree imposes destination‑based taxation on non‑resident suppliers, requiring registration and tax collection on B2C sales, while B2B transactions are subject to reverse charge. Platforms that facilitate services become deemed suppliers, responsible for collecting and remitting CBS.

ZUGFeRD 2.5 will be released on 20 May 2026 for Germany and France, adding native support for gross invoicing and aligning with the latest EN 16931 code lists. The update also expands reference templates for construction, leasing, reverse charge and simplified invoices, and reinforces cross‑border participation through an English version of the ZR framework.

The UK government has introduced a new VAT road fuel charge regime effective from 1 May 2026, applying to all VAT‑registered businesses that reclaim VAT on fuel used for private company car use. The charges vary by vehicle CO2 emissions and accounting period, with rates ranging from £54 to £190 per month or £657 to £2,297 per 12‑month period. Businesses must calculate the correct charge based on CO2 emissions or engine size if no CO2 figure is available.

Grenada will introduce a 10% VAT on digital services supplied by non‑resident platforms, SaaS, streaming, cloud computing, e‑learning and online advertising, effective 2027. The law includes a deemed‑supplier regime for electronic marketplaces, a B2B reverse charge, and requires B2C non‑resident suppliers to register and charge VAT. A six‑month transition period is expected after approval, with no current implementation date.