The VATfaqs digest
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HMRC has introduced a new requirement for UK VAT registration, effective 19 January 2026, that businesses must provide the unique VAT registration application reference number before adding VAT to a Business Tax Account. This step aims to close a fraud window where criminals linked VAT numbers to Government Gateway accounts before the legitimate owner could log in. Businesses should safeguard the reference number and act swiftly after registration to mitigate fraud risks.
Saudi Arabia’s Zakat, Tax and Customs Authority (ZATCA) has issued amendments to the VAT Implementing Regulations that clarify the responsibilities of electronic marketplaces and e-commerce platforms. The changes define when a marketplace is deemed to facilitate a supply and therefore liable for VAT, and introduce phased effective dates for compliance. Businesses operating in the Kingdom should review their operating models and contractual arrangements to ensure alignment with the updated framework.
Global e-Invoicing Requirements Tracker
Canada Revenue Agency has reversed its 35‑year position, treating mutual fund trailer commissions as subject to GST/HST. The change will take effect on July 1, 2026, requiring dealers to collect and remit the tax, while managers can recover it as input tax credits. Industry groups argue the implementation deadline is unrealistic and the change adds costs without revenue benefits.
The article discusses Canada’s new Canada Groceries and Essentials Benefit, a top‑up to the GST credit announced by Prime Minister Mark Carney on January 26, 2026. The benefit totals $11.7 billion over six years, covering 12 million people, and recipients can spend the money on any goods or services. The benefit does not affect grocery GST, which remains exempt except for snacks.
Portugal’s government has drafted a bill to cut VAT on construction for own permanent housing to 6%, but the Portuguese Association of Chartered Accountants (OCC) deems the proposal unworkable due to its reliance on post‑construction third‑party checks. The bill would apply only to properties for own use with a sale value not exceeding €648,000, and would require contractors to issue zero‑VAT invoices with developers self‑assessing. OCC warns that the uncertainty could force builders to absorb the difference between 6% and the standard 23% rate.
The European General Court issued an order on 21 January 2026 in Case No. T-394/25, upholding the EU VAT deemed supplier model that requires online platforms to collect and remit VAT for short‑term accommodation rentals. The court found the taxpayer’s challenge inadmissible under the Treaty on the Functioning of the EU. This decision confirms the compliance obligations for platforms operating in the EU short‑term accommodation market.
Canada has increased the maximum GST credit from $700 to $900 to help low‑income families cope with high food inflation. A family of four could receive up to $1,890 this year and about $1,400 annually for the next four years. Eligibility is based on filing a tax return, and the change comes amid a 6.2% food inflation rate in December 2025.
The United Nations has released a new publication that consolidates four guidance papers aimed at strengthening VAT/GST systems in developing countries. The guidance covers fundamentals, small enterprises, refunds, and technology and compliance, including e‑invoicing, electronic reporting and big‑data analytics. It encourages tax administrations to adopt technologies thoughtfully rather than as one‑size‑fits‑all solutions.
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 European General Court dismissed an Italian association’s challenge to EU VAT directives that impose a deemed‑supplier model on digital platforms for short‑term accommodation rentals. The court held the association lacked direct and individual concern, as the rules target platform operators, not property owners. The decision confirms the applicability of Directive (EU) 2025/516 and Regulation (EU) 2025/518.
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.
The Bombay High Court ruled that a minimum three‑month gap must exist between a Section 73(2) show‑cause notice and the final order under Section 73(10) in GST proceedings. Orders passed earlier, such as the two‑and‑a‑half‑month order in the A.M. Marketplaces case, were quashed. The decision underscores procedural fairness and the need for adequate time for taxpayers to respond.
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.
The OECD has renewed its call for Australia to broaden and potentially raise the GST to improve fiscal sustainability. It recommends expanding the tax base and considering a rate increase above the current 10%, possibly up to 15% if paired with income‑tax cuts, and estimates a 1.6% boost to output over ten years. The recommendation comes ahead of the May federal budget and follows a mid‑year budget update that confirmed persistent deficits.
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.