Global VAT Guide: May 2026

The May 2026 edition of the Global VAT Guide brings together key VAT developments across Belgium, Bulgaria, Germany, Poland, Slovakia, Nigeria, South Africa, Sri Lanka, Switzerland, Turkey, Ukraine and the United Kingdom.

This month’s update shows authorities placing greater emphasis on digital processes, stronger compliance controls and frameworks. We’re seeing continued expansion of eInvoicing and digital reporting schemes, especially in Poland. Other digital transformation efforts are underway in Switzerland and Turkey.

Updates in Nigeria and Ukraine reflect increased scrutiny on digital services and ecommerce. We’re also seeing tax authorities actively adjusting VAT registration thresholds to balance compliance and economic growth.

Use this summary to stay informed of the latest regulatory changes, effective dates and compliance implications for your business.

Belgium

New bank account for periodic VAT payments

The Belgian Tax Authorities have confirmed a change to the bank account used for paying periodic VAT.

From 1 May 2026, all periodic VAT payments must be made to the new bank account listed below.

IBAN: BE41 6792 0036 4210

BIC: GEBABEBB

This new account replaces the previously used bank account (IBAN: BE22 6792 0030 0047), which was valid until 30 April 2026.

Taxpayers should ensure that all future VAT payments are made to the new account to avoid any processing issues or delays.

Belgium

SME scheme ePortal opens for quarterly VAT returns

The Belgian Tax Administration has announced that the ePortal for submitting quarterly VAT returns under the SME scheme is now live, as of 1 April 2026.

Small businesses registered under Beligum’s SME scheme (a special tax exemption regime) that received an individual identification number with the suffix “EX” can submit their returns via the Intervat SME module starting from this date.

The Tax Authorities also remind businesses that SME quarterly returns must be filed within the statutory deadlines.

Failure to comply may result in the revocation of the exemption by the relevant Member State, which could have wider VAT compliance consequences.

Bulgaria

VAT treatment of goods supplied with installation

Bulgaria has introduced important changes to its VAT rules that affect the supply of goods with assembly or installation. These changes were introduced through an amendment to the Bulgarian VAT law, published in the Official Gazette on 30 December 2025 and effective from 1 January 2026. The amendment forms part of a wider reform including new national and EU-wide VAT thresholds and measures implementing the EU SME Directive.

One key change affects how VAT is accounted for when goods are supplied with installation or assembly in Bulgaria. Previously, Bulgarian VAT law explicitly included supplies of goods assembled or installed by, or on behalf of, a supplier established in another Member State among the transactions subject to the reverse charge mechanism. Under this mechanism, the Bulgarian VAT-registered customer was responsible for accounting for VAT. From 1 January 2026, this explicit clause has been removed from the legislation.

As a result of this change, EU traders carrying out such activities should reassess the VAT treatment of their supplies in light of these amendments.

In particular, they need to determine whether a VAT registration obligation arises in Bulgaria and consider the appropriate method for recovering input VAT.

For some businesses, this change may affect how VAT is reclaimed. Recovery may no longer be possible through the EU VAT refund procedure set out in Directive 2008/9/EC. Instead , input VAT recovery may require local VAT registration and ongoing VAT reporting obligations.

Germany

Updated Form Ust 1 TN for proof of VAT registration

Germany has introduced an updated version of Form USt 1 TN, the template used as proof of registration as a taxable person for VAT purposes.

On 23 April 2026, the Ministry of Finance published a BMF (Bundesministerium der Finanzen) letter confirming the changes.

The changes compared to the previous version are of an editorial nature and include:

• Removal of the field for the official seal
• Deletion of the statement “This letter was generated automatically and is valid without a signature”.

No other amendments have been made.

Taxpayers should ensure that the updated version of the form is used going forward, where applicable.

Poland

JPK_VAT reporting – Updated guidance on document types

Poland’s Ministry of Finance has issued updated guidance on how certain document types should be reported in JPK_VAT (the Polish Standard Audit File for VAT), with a particular focus on foreign invoices and the National e‑Invoice System (KSeF).

The clarification was published on 7 April 2026 and applies to both sales and purchase reporting.

The guidance explains when and how to use specific document type markings in JPK_VAT, including:

• BFK
• DI
• OFF
• NrKSeF

Correct use of these indicators is essential to ensure VAT records align with KSeF and Polish VAT reporting rules.

Foreign invoices and internal documents

Document type BFK

Foreign invoices should be marked as Document Type “BFK” where, for example, a foreign supplier provides services taxable in Poland for which the Polish business recipient is required to account for Polish VAT.

BFK is also used for electronic or paper invoices issued outside KSeF in specific situations, including:

• Invoices issued during a total KSeF failure
• Invoices issued before KSeF becomes mandatory for a particular taxpayer or transaction type
• Correction invoices relating to bad debt relief
• Intra-Community acquisition of goods (WNT) and import of services
• Import of goods settled under Article 33a of the VAT Act
• Supplies where the purchaser is liable for VAT under Article 17(1)(5) of the VAT Act

Document type DI

Where no invoice is issued, the transaction should be settled using an internal document and marked as Document Type “DI”. These entries should be reported as WEW in JPK_VAT, in line with existing guidance on internal evidence.

The DI designation applies in particular to:

• Documents other than invoices, including internal documents and collective cash register reports
• Transactions not covered by BFK or OFF
• WNT and import of services documented by means other than an invoice (reported as WEW)
• Import of goods under Article 33a of the VAT Act
• Supplies where the purchaser is the taxpayer under Article 17(1)(5) of the VAT Act

KSeF indicators: NrKSeF and OFF

NrKSeF

The NrKSeF field must be completed where:

• An invoice has been issued via KSeF
• A KSeF number has been assigned by the time JPK_VAT is submitted

This applies across all issuance modes, including:

• offline24
• Failure mode
• System unavailability

As long as the invoice has been transmitted to KSeF and received a number, NrKSeF must be reported.

OFF

The OFF indicator is used where:

• No KSeF number is available due to technical reasons at the time of submission of VAT records.

There is no obligation to correct JPK_VAT once the KSeF number is later obtained.

Special rules for offline and unavailable KSeF scenarios

Invoices issued:

• In offline24 mode (Article 106nda of the VAT Act), or
• During system unavailability (Article 106nh(1) of the VAT Act)

and which do not yet have a KSeF number at the time of reporting, should initially be marked as DI.

If these invoices are provided to the buyer outside KSeF and reported as DI, the taxpayer must correct the JPK_VAT once the KSeF number is received by updating the document marking.

Purchases: additional clarifications

For purchases reporting, the Ministry confirmed DI applies to:

• All documents other than invoices
• Documents with no KSeF number
• Documents not submitted to KSeF
• Documents that cannot be classified as BFK or OFF, but still require VAT reporting

This also includes VAT‑RR documents issued outside KSeF.

As KSeF and JPK_VAT continue to evolve, keeping document classifications aligned with official guidance is essential to avoid reporting errors and follow‑up from the tax authorities.

Poland

Public consultation on VAT refund rules for foreign taxpayers

Poland has launched a public consultation on proposed changes to the VAT refund rules for foreign taxpayers, aimed at aligning the refund process with the mandatory National eInvoice System (KSeF).

The consultation was opened on 15 April 2026 by the Ministry of Finance and Economy and covers both EU and non‑EU claimants.

The draft regulation updates the existing VAT Refund Regulation to reflect the fact that, as a rule, invoices documenting supplies of goods and services in Poland will be issued via KSeF.

Under KSeF, invoices may be made available to purchasers in different formats, depending on the applicable invoicing rules. The draft acknowledges this and clarifies how foreign taxpayers should evidence their VAT refund claims in a mandatory eInvoicing environment.

Impact on invoice submission with refund claims

Given the widespread use of mandatory eInvoicing, the general obligation to attach invoices to VAT refund applications is expected to be relaxed.

Where invoices are issued via KSeF

Under the draft regulation, EU and non‑EU claimants will be required to provide KSeF invoice identification numbers with their VAT refund application, where available.

Where KSeF invoice numbers are not provided

If KSeF invoice identification numbers are not provided in the refund application different rules apply depending on the claimant’s location.

• EU claimants will be required to submit copies (reproductions) of invoices received (paper or electronic) via electronic communication together with the application.

• Non-EU claimants
  • Must attach paper invoices to the refund application
  • Must send or otherwise make available electronic invoices to the Polish tax authorities at the time of submission (e.g. via email).

The draft regulation also includes some transitional provisions to clarify which rules apply depending on the refund period and timing of submission:

• Existing rules will continue to apply to VAT refund applications relating to periods before 1 January 2026 (i.e. invoices issued in 2025).
• The amended rules will apply to refund applications for periods starting from 1 January 2026 (i.e. invoices issued in 2026), provided that the applications are submitted after the new regulation enters into force
• For quarterly refund applications submitted before the regulation enters into force, the current rules will continue to apply, even if the refund period relates to 2026.

The draft regulation is expected to enter into force on the day following its publication.

Businesses affected by these changes should monitor developments closely and assess the impact on their VAT refund processes, particularly in relation to KSeF invoice identification requirements.

Slovakia

Proposed amendments to VAT registration

Slovakia is considering an increase to its VAT registration thresholds, which could reduce the number of smaller businesses required to register for VAT.

At the beginning of February 2026, a draft amendment to the Slovak VAT Act (No. 222/2004 Coll.) was submitted to the National Council (Národná rada) of Slovakia. The proposed amendment addresses changes to the VAT registration thresholds under Article 4 of the VAT Act.

The draft amendment includes two key threshold increases, both calculated excluding VAT:

• The threshold for mandatory registration based on the value of goods or services supplied in the previous calendar year would increase from €50,000 to €83,000.
• The threshold for immediate registration based on the value of goods or services supplied in the current calendar year would increase from €62,500 to €85,000.

These thresholds determine when a business must register for VAT in Slovakia.

The draft legislation proposes an effective date of 1 July 2026.

The draft is currently under review by the National Council.

Nigeria

Guidance for non-resident taxpayers and VAT obligations

Nigeria has issued new interim guidance clarifying the tax obligations of non‑resident entities and individuals, including specific rules on Value Added Tax (VAT).

On 31 March 2026, the Nigeria Revenue Service (NRS) issued a letter setting out how non-resident taxpayers should comply with Nigerian tax law, pending the release of detailed circulars and regulations under the new tax reform framework.

The guidance outlines the tax obligations for non-resident taxpayers, with a particular focus on the digital sector.

According to the NRS, non‑resident entities operating in the digital sector and designated as VAT collection agents are required to:

• Use their platforms to charge and collect Nigerian VAT
• Apply this obligation to all Nigerian counterparties, including:
  • Business‑to‑business (B2B)
  • Business‑to‑consumer (B2C)
  • Business‑to‑government (B2G)

This requirement applies even where the Nigerian counterparties have also been appointed as VAT collection agents.

The guidance also outlines the tax treatment of several other categories of non‑resident taxpayers.

Non-resident entities earning passive income

For non-resident entities earning only passive income in Nigeria

• Where that income is subject to withholding tax as a final tax are generally not required to file annual Companies Income Tax (CIT) returns.
• However, they are encouraged to register on the TaxPro Max platform to access withholding tax credits.
• These credits may serve as proof of tax paid in Nigeria for foreign tax credit claims and to mitigate double taxation where applicable.

Non-resident entities with a Permanent Establishment (PE) or Significant Economic Presence (SEP)

Non-resident entities with a PE or SEP in Nigeria are required to file CIT returns and comply with VAT obligations, including registration, charging, collection and monthly remittance.

Such entities are subject to the same tax obligations as resident companies, except for the Development Levy.

Non-resident entities under Double Taxation Treaties (DTTs)

Entities seeking relief under applicable DTTs must file the relevant tax returns and obtain approval from the Competent Authority before claiming treaty benefits. DTT relief does not exempt entities from filing obligations. Failure to meet filing requirements may prevent access to treaty benefits.

Non-resident investors in the Nigerian capital market

These investors are encouraged to file tax returns within one month of disposing of chargeable assets via the TaxPro Max platform.

They may request access to the appropriate forms to facilitate compliance.

Non-resident aviation and shipping companies

Such companies are required to file monthly CIT returns calculated at 2% of both freight and non-freight income. In addition, submit annual tax returns within six months after the end of their financial year. The TaxPro Max platform is available to support compliance.

While further regulations are expected, non‑resident businesses should review this guidance carefully and assess how it affects their VAT registration, collection and reporting processes in Nigeria.

South Africa

VAT registration threshold increase

South Africa has officially increased its VAT registration thresholds.

On 2 April 2026, the South African Revenue Service (SARS) published the Budget 2026 Frequently Asked Questions, summarising key information on taxes, duties and levies. This confirmed the VAT registration updates previously mentioned in the March 2026 Global VAT Guide.

From 1 April 2026, the threshold for compulsory VAT registration has increased from ZAR 1 million to ZAR 2.3 million per annum.

Businesses whose taxable supplies exceed ZAR 2.3 million in any twelve‑month period are required to register for VAT in South Africa.

SARS has also increased the threshold for voluntary VAT registration.

From 1 April 2026, taxpayers may apply for voluntary registration where:

• Taxable supplies exceed ZAR 120,000 per annum, and
• Taxable supplies do not exceed ZAR 2.3 million per annum

There is no change to the VAT rate. The standard South African VAT rate remains at 15%.

Sri Lanka

Further postponement of VAT on digital services by non-resident providers

Sri Lanka has announced a further postponement to the introduction of VAT on digital services supplied by non‑resident providers.

On 31 March 2026, the Sri Lankan Tax Authorities issued a notice announcing a further postponement of the effective date for the imposition of VAT on the supply of digital services provided through electronic platforms by non-resident service providers.

According to the notice, the implementation of VAT on such services has been postponed until 1 July 2026, subject to a formal amendment to the VAT Act.

Taxpayers affected by this measure should take note of the revised timeline and monitor for any further legislative developments or implementing guidance.

Sri Lanka

New VAT invoice format approved

Sri Lanka has approved a new format for VAT invoices, introducing more detailed and structured invoicing requirements.

The Inland Revenue Department approved the new VAT invoice format in November 2025, with the specifications published in Official Gazette No. 2463/05 on 17 November 2025. The changes introduce more detailed specifications for existing invoice fields and add several new mandatory elements.

Key changes include:

• A strictly defined invoice number format
• The total consideration must be stated both numerically and in words
• A telephone number is now required for both the issuer and the recipient
• The place of supply and the method of payment must be indicated
• Each required data element is assigned a dedicated field within the invoice layout.

Although the new format and specifications were initially scheduled to take effect in January 2026, implementation has been postponed twice. The latest update, published on the Inland Revenue Department’s website on 31 March 2026, confirms that the new VAT invoice format will now take effect from 1 July 2026.

Until then, businesses may continue using the existing VAT invoice format, but should use the additional time to prepare their systems for the more structured requirements coming later this year.

Switzerland

Migration of VAT e-services to new FTA portal from May 2026

Switzerland is migrating its VAT‑related e‑services to a new online platform.

According to a press release issued by the Swiss tax authorities on 11 April 2026, VAT-related e-services will begin to moving to the new e-tax (FTA) portal from May 2026, with the with the first services going live on 11 May 2026.

The new portal will act as a single access point for a wide range of tax‑related online services. It will consolidate permissions and services that are currently spread across the existing ePortal into one centralised platform.

The migration of services will be carried out gradually.

From 11 May 2026, the following services will be available via the FTA portal:

• myFTA (registration and management of businesses and individuals)
• VAT registration
• Submission of VAT returns via “VAT return pro”
• VAT certificates
• Radio and television fee services
• Withholding tax and stamp duty services

The FTA portal can be accessed via the “Login” option on the ePortal homepage or by selecting the relevant tax service on the tax authority’s website or within the ePortal

As part of this transition, the “VAT return easy” service will be discontinued.

In addition, the tax calculator will no longer be integrated within the ePortal. This can be accessed via the FTS website or at swisstaxcalculator.estv.admin.ch.

Businesses using Swiss VAT e‑services should familiarise themselves with the new portal and plan for the transition as services are progressively migrated.

Turkey

Phased rollout of e-Beyan system for VAT returns

Turkey is continuing the phased rollout of its upgraded e‑Beyan (e‑Declaration) system for VAT returns.

On 17 April 2026, the Turkish Tax Authorities announced a further expansion of the “e-Beyan” (“e-Declaration”) system as part of the ongoing upgrade of the Electronic Declaration Application using new, up-to-date, open-source software.

The following VAT return forms—KDV1, KDV2, KDV2B, KDV4, and KDV9015—are already being submitted via the new e-Declaration functionality in a number of provinces:

• Since 1 September 2025: pilot provinces Eskişehir and Kırşehir
• Since 1 November 2025: Konya and Muğla
• Since December 2025: Afyonkarahisar, Bursa, Kırıkkale, and Yalova
• Since March 2026: Bartın, Bilecik, Karabük, Karaman, Amasya, Burdur, Bolu, Kastamonu, Niğde, and Yozgat

As part of the continued rollout, the e-Declaration application will become mandatory from 1 May 2026 for taxpayers in the provinces of İzmir, Adana, Gaziantep, and Mersin. For these provinces, the e‑Declaration application must be used to submit April 2026 VAT returns and all subsequent periods.

Taxpayers in these provinces must file VAT returns via the Digital Tax Office, selecting the relevant return types under the “+ New Declaration” section (0015-KDV1, 4017-KDV2, 4018-KDV2B, 0016-KDV4, and 9015-KDV9015).

In addition, professionals operating in provinces included in the pilot program may submit VAT returns on behalf of their clients through system integration (web services), provided their accounting software is compatible with the e-Declaration system.

The necessary technical documentation has been made available to software providers requesting integration.

Further detailed guidance on completing VAT returns is available in the dedicated Help section within the e-Declaration application.

Ukraine

Draft law proposes new VAT rules for ecommerce transactions

Ukraine is proposing significant changes to its VAT framework for e‑commerce.

On 3 April 2026, the Ukrainian Parliament published Draft Law No. 15112-1 proposing amendments to the Tax Code of Ukraine to introduce new VAT rules on e-commerce transactions.

The proposal aims to align national legislation with the principles of EU Council Directive 2006/112/EC, under which sellers operating via electronic interfaces, or their intermediaries, may in certain cases be treated as suppliers for VAT purposes.

The draft law introduces a special VAT regime for remote sales of goods (excluding excisable goods) where the total invoice value does not exceed the equivalent of €150.

This applies to goods dispatched from outside Ukraine to the customs territory of Ukraine and supplied to private individuals via electronic platforms. The proposal also clarifies that VAT on such remote sales may be collected at source, rather than through post‑import mechanisms.

In addition, the draft law also clarifies that VAT exemption on the import of goods with a total invoice value of up to €45 per recipient per shipment, provided that:

• The goods are sent without payment
• They are intended for personal or family use
• Their nature, quantity and frequency do not indicate a commercial purpose

These conditions are in line with the provisions of Council Directive 2006/79/EC.

To support VAT collection on e‑commerce transactions, the draft introduces new responsibilities for electronic interface operators, including non‑resident platforms. These include:

• Obligations to maintain records of distance sales of goods
• Rules determining who is responsible for collecting and paying VAT due on distance sales made via electronic interfaces
• A provision that, where the underlying seller is a non-resident, the intermediary (electronic platform operator) is deemed responsible for charging and remitting VAT to the budget.

The draft law is intended to strengthen VAT collection mechanisms in e-commerce and align Ukraine’s VAT system with EU approaches to platform-based trade.

United Kingdom

Mandatory registration for tax advisors interacting HMRC

Tax advisors interacting with HMRC on behalf of clients will be required to register from 18 May 2026 and comply with a set of specified conditions, as set out in HMRC guidance published in mid-February 2026 and last updated on 26 March 2026,

1. To register, tax advisors must meet all of the following requirements:

• No relevant outstanding tax returns or unpaid tax (unless covered by a payment plan)
• Not subject to an HMRC refusal to deal with the adviser
• Not subject to anti-avoidance sanctions or a stop notice
• No relevant unspent convictions for fraud or tax offences
• Not formally insolvent
• Not suspended or permanently banned from HMRC registration

2. The business must provide evidence that the business is supervised for Anti-Money Laundering (AML) purposes.

3. Where an organisation has six or more officers, at least five “Relevant Individuals” involved in tax advisory services must be nominated.

HMRC requires registration for an Agent Services Account within three months from 18 May 2026, subject to the following phased application:

• From 18 August 2026: applies where a Self Assessment or Corporation Tax account is already held
• From 18 November 2026: applies to businesses providing only third-party payroll services and not interacting with HMRC in any other capacity
• From 31 December 2026: applies to financial services organisations only

The online registration service will be available from 18 May 2026, including for those not yet required to register until a later date.

During the three-month registration window, affected businesses may continue to interact with HMRC on behalf of clients.

Non-established tax advisors must provide authenticated evidence when registering for an Agent Services Account.

HMRC has indicated that further guidance will be issued in due course setting out detailed registration steps and procedural requirements.

HMRC expands multi-factor authentication for agents

As mentioned in the April 2026 Global VAT Guide HM Revenue & Customs (HMRC) has updated its guidance for tax agents as it prepares to roll out multi‑factor authentication (MFA) across agent accounts.

On 31 March 2026, HMRC updated the Tax Agent’s Handbook section on Multi-Factor Authentication (MFA), adding futher detail on preparation steps, the use of third-party software, the “remember me” function, and access code arrangements. The update follows a successful test‑and‑learn phase involving a small group of agents.

HMRC confirmed that MFA testing will be expanded during April and May 2026, with MFA to be applied to all agent accounts once testing is complete. The final implementation date has not yet been confirmed.

HMRC advises agents to prepare to avoid disruption to access to online services.

Recommended actions include:

• Setting up individual accounts for each member of staff
• Ensuring at least two administrators are in place
• Removing accounts that are no longer required
• Reviewing how access codes will be received and configuring a secondary backup method

HMRC outlines the following authentication methods:

• Authenticator app – Can be used on a phone, tablet or computer; works without mobile signal, generates time-limited codes and can be used offline
• Text message – codes are valid for 15 minutes and requires mobile signal to receive
• Voice call – codes are valid for 15 minutes, the user receives a call and hears the code via an automated voice message

HMRC recommends using an authenticator app as the primary method, supported by at least one additional backup option.

Agents are also advised to check and update existing MFA settings.

In some cases, MFA may already have been enabled previously (for example, through services such as Making Tax Digital for VAT), and access codes will be sent to the contact details recorded at the time of setup. Agents should review and update their account details where necessary.

Administrators can remove outdated MFA settings, but cannot set up new authentication methods on behalf of users. Individual users will be required to configure new MFA options at their next login.

HMRC has also noted that agents using automated processes or third‑party software may be affected. In these cases, agents should contact their software provider to confirm compatibility with MFA and any required changes.

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