Global VAT Guide: October 2026

The October 2026 edition of the Global VAT Guide brings together key VAT developments across Croatia, Czech Republic, Dominican Republic, France, Germany, Greece, Italy, Lithuania, Netherlands, Romania, Slovakia, UAE, and United Kingdom.

This month’s update is particularly focused on eInvoicing changes taking effect for the rest of the year into January 2027. For businesses operating across these jurisdictions, the immediate priority is managing a series of different implementation models and deadlines rather than preparing for one common form of eInvoicing.

We are also seeing tax authorities making greater use of data already available to them. Alongside these digital developments, there are also practical VAT changes requiring attention so its important to assess the operational impact of October 2026 changes to the products or markets in which you operate.

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

Croatia

Croatia amends the fiscalisation procedures of invoices and sales from 1 January 2027

Croatia has updated its fiscalisation requirements for invoices and sales made through self-service devices. The changes were introduced by Ordinance on Amendments to the Ordinance on Fiscalization of Final Consumption Accounts, published in the Official Gazette No. 97/26 published on 2 September 2026.

The amended rules take effect from 1 January 2026 and are intended to align existing terminology with the EU regulation No.910/2014. on electronic identification and trust services.

The amendments of the rules cover the following topics:

• The entity, subject to the fiscalisation of invoices must obtain a digital certificate containing its personal identification number (OIB)
• The digital signature must be issued by a trust service provider when applying an electronic signature
• A 32-character record in hexadecimal format (numbers and lowercase letters) must be generateD and printed on invoices
• The addition of the following payment methods: card, mobile application or other similar payment methods
• The amendments cover the replacement of phrases with “trust service provider” and “digital certificate”, and the removal of specific legacy terminology.

Croatia updates MICROeRacun ahead of mandatory eInvoicing

The Croatian Tax Administration has upgraded the MICROeRacun application to help businesses meet new eInvoicing obligations from 1 January 2027.

The MICROeRacun application currently allows users to receive, review, search, reject and store eInvoices through the ePorezna System, as well as the fiscalise the receipt and rejection of invoices. The upgraded version will be available for testing during October 2026.

The changes support the next phase of Croatia’s mandatory eInvoicing rollout, which will apply from 1 January 2027 to taxpayers who are not registered for VAT. Many of the core compliance eInvoicing requirements were already introduced during 2026.

Key eInvoicing requirements

• Fiscalisation of issued and received eInvoices: Croatia requires fiscalisation to be completed separately from the eInvoice exchange process.
  • The issuer of eInvoices must fiscalise eInvoices when they are issued for issued
  • In the case of self-issuance of invoices, fiscalisation must take place no later than five working days after the eInvoice has been issued.
• Reporting rejected invoices: There is no deadline for rejecting an invoice. However, recipients must report all declined documents to the Fiscalization System by the 20th day of the following month. Submitting this data legally declares that the buyer waives the right to claim Input VAT on those transactions.
• Scope of the mandate: The obligation to issue and fiscalise eInvoices applies exclusively to domestic transactions between taxpayers established in Croatia, including those with:
  • A registered office in Croatia
  • Permanent residence in Croatia
  • Habitual residence in Croatia
• Additional invoice content requirements: eInvoices must include@
  • Information relating to goods and services supplied
  • The correct classification code from Croatia’s National Classification of Activities (KPD)
  • A six digit numerical KPD code within the eInvoice
• Digital certificate requirements: As mentioned previously, the issuer and recipient of an einvoice must use a digital certificate that includes the OIB of the person authorised to submit fiscalisation messages. This authentication setup must be used to submit the mandatory monthly reporting data (such as invoice rejections and billing information) to the Fiscalization System by the 20th day of the month for the previous month
• Currency and exchange rate rules: Amounts shown on eInvoices must be in euros and may also be shown in any other currency, provided that the amount of VAT to be paid or to be adjusted is stated in euros using the exchange rate. When an eInvoice is issued in a foreign currency, all amounts used for fiscalization must be converted into euros using the appropriate exchange rate. The XML scheme (XSD) accepts monetary value in euros only.

Exemption from mandatory eInvoicing

The mandatory eInvoicing rules do not apply to:

• Cross-border transactions
• Non-established entities
• Specific public and utility sectors (electricity, gas, water, toll collection, financial services, public transport, etc.)
• System outages

Read our full blog on Croatia’s next phase of eInvoicing here.

Czech Republic

Changes in the VAT Act from January 2027

On 9 September 2026, the Czech Parliament passed the Law on the Registration of Sales and on the Amendment of Certain Other Acts, introducing several changes to VAT Act No. 235/2004 Coll.

Key VAT changes include:

• Removal of the input VAT deduction cap for selected passenger cars (category M1);
• Alignment of the VAT treatment of restaurant and catering services and the supply of non-alcoholic beverages, all subject to the reduced VAT rate of 12%.

Under the current rules:

• Input VAT on the acquisition and technical improvement of selected passenger cars (category M1) is limited to CZK 420,000; and
• The supply of non-alcoholic beverages is subject to the standard VAT rate of 21%.

The law was signed by the President on 17 September 2026 and will enter into force on 1 January 2027.

Dominican Republic

Mandatory eInvoicing for large and medium taxpayers from 1 November 2026

The Dominican Republic is moving to full electronic invoicing for large local and medium-sized taxpayers. Under Notice 14-26, issued by the General Directorate of Internal Taxes (DGII) on 26 August 2026, affected taxpayers must exclusively issue electronic invoices using Electronic Tax Receipts (e-CF) from 1 November 2026.

Existing Type B non-electronic tax receipt sequences assigned to these taxpayers will remain valid only until 31 October 2026. After that date, Type B receipts may only be used where a taxpayer has declared a contingency situation in accordance with Chapter IX of Decree No. 587-24. Failure to comply with eInvoicing may result in penalties under Article 27 of Law No. 32-23 on Electronic Invoicing.

Alongside the upcoming eInvoicing mandate, the DGII has modified its withholding framework to benefit companies using the electronic system. Under General Rule No. 02-2026, effective 16 September 2026, companies acting as withholding agents of the Tax on the Transfers of Industrialized Goods and Services (ITBIS), under General Rule No. 02-05, are no longer required to withhold ITBIS when making payments to another legal entity, provided that the legal entity is an authorised electronic invoice issuer and the transaction is billed using an Electronic Tax Receipt (e-CF).

This exclusion applies exclusively to the withholdings established in General Rule No. 02-05 and does not affect withholdings or tax collections mandated by other legal provisions.

France

New invoice requirements for eInvoicing from 1 September 2026

France’s eInvoicing mandate went live from 1 September 2026, all companies within scope must now must issue, transmit and receive electronic invoices through an approved platform. As part of these changes, invoice content requirements are being expanded to include four additional data fields.

• The customer’s SIREN number (the French business identification number)
• Nature of the transactions invoiced – goods, servicesor both
• A statement confirming the option to account for VAT on debits, where applicable (appearing only on certain invoices depending on the transaction)
• Delivery address of the goods, if different from the customer’s billing address

Although the new invoice fields form part of France’s eInvoicing framework, the French Tax Authorities will not collect all information contained within an invoice.

Instead, only the data considered necessary for tax administration purposes, including the pre-population of VAT returns, will be transmitted to the authorities. The collection of data required in a specific structured format will be phased in between 1 September 2026, and 1 September 2027 (26 mandatory data items in 2026, increasing to 34 data items from 2027 onwards).

The approved platform used by the invoice issuer will be responsible for extracting and transmitting only the invoice data required by the French Tax Authorities.

The new invoice requirements are reportable to the tax authorities from 1 September 2026, except for “Delivery address”, which becomes reportable from 1 September 2027.

Germany

Germany’s next mandatory eInvoicing phase from 1 January 2027

Germany is preparing to enter the next critical phase of its national B2B eInovicing (E-Rechnung) rollout. set to take effect from 1 January 2027. From 1 January 2027, additional businesses will be required to comply with the country’s electronic invoicing requirements as part of the phased implementation programme introduced by the Federal Ministry of Finance (BMF).

The 2027 deadline marks the next stage in Germany’s transition towards mandatory electronic invoicing for domestic B2B transactions, following the initial introduction of e-Invoice receipt obligations in 2025.

To get a full breakdown of the transition periods and key implementation requirements, check out our full bog here.

Germany

Tax Authority updates VAT registration forms for non-resident businesses

Germany has published revised VAT registration forms for non-resident businesses (FsEAusUN01)

The updated forms reflect current legislation, including the EU Small Business Scheme under § 19(4) UStG, e-commerce marketplace provisions, VAT ID requirements and OSS reporting mechanisms.

Greece

Greece postpones next phase of mandatory eInvoicing to 2 November 2026

Greece has postponed the next phase of its mandatory eInvoicing programme and the second phase of digital stock movement monitoring. The change was announced on 30 September 2026 in a joint decision by the Deputy Minister of National Economy and Finance and the Governor of the Independent Authority for Public Revenue (AADE).

The postponement concerns businesses that have declared gross revenue of up to €1 million, based on the tax return submitted for the tax year that began in 2023.

To date, almost 70% of businesses businesses in scope for this phase are already using an electronic invoicing provider or AADE applications for wholesale transactions.

In the last month alone, almost 488,000 businesses submitted the relevant declaration or adopted an approved eInvoicing solution.

Revised implementation timeline for Greece eInvoicing

Date	Requirement
2 November 2026	Mandatory eInvoicing phase begins
2 November 2026 to 31 January 2027	Transitional implementation period, allowing the parallel use of business management systems (including commercial, accounting and ERP systems) or the special registration form
1 February 2027	Exclusive use of approved eInvoicing channels becomes mandatory

How businesses can comply with Greece’s eInvoicing mandate

• Through an electronic invoicing provider service, or
• AADE’s free applications, timologio and myDATAapp for mobile devices, which also cover issuance of eInvoices for public contracts.

Businesses choosing to use an electronic invoicing provider must submit a Declaration of Commencement of Electronic Issuance of Data with an effective date of 2 November 2026 and start issuing electronic invoices during the transitional period (2 November 2026 – 31 January 2027).

Starting 1 February /2027, the issuance of eInvoices (domestic B2B transactions and with a third country outside the EU, B2G transactions) and the transmission of the relevant data to the myDATA digital platform, will be carried out exclusively using Electronic Invoicing Provider Services or the AADE applications timologio and myDATAapp. From this date it will not be possible to transmit the data of these documents to the myDATA platform in any other way (for example through an ERP).

The digital monitoring of stock movement will be implemented for all businesses as follows:

• 1 January 2027: The loading, transshipment and receipt procedures for the digital monitoring and traceability of stock movement, as well as the transmission of quantitative control data, are activated.
• 1 January 2028: The Unified Coding of Species is applied, according to the Combined Nomenclature (TARIC).

Italy

Italy implements automated VAT assessments for missing annual VAT returns

Italy has introduced a new automated process for identifying and assessing VAT liabilities where an annual VAT return has not been submitted.

The Italian Revenue Agency (Agenzia delle Entrate) has issued an official implementing provisions of Article 54-bis.1 of Presidential Decree No.633/1972. The rules signed on 28 August 2026 define the implementation methods of automated VAT liquidations for omitted annual returns.

In the absence of an annual VAT return, the Agency can determine the tax due through automated procedures based on data already acquired by the Administration through electronic invoices issued and received, telematic daily closure, communications of periodic liquidation data (LIPE) and VAT payments relating to the tax period concerned.

The data can be consulted by the taxpayer and any delegated intermediary through the “Invoices and Considerations” portal, while information on payments is available in the Tax Drawer.

The tax due is determined as the difference between the VAT payable and the VAT credited resulting from the above-mentioned information sources, net of any payments made. A penalty for failure to declare will also be added to payment amount.

Penalties, deadlines and conditions:

• 4% interest rate per year
• Administrative penalty equal to 120% of the calculated tax liability

However, reduced penalties are available where the taxpayer settles the amounts promptly.If taxpayer makes payment within 60 days from the receipt of the communications or the re-settlement carried out – the administrative penalty is reduced to a one-third (40%) and the interests rate dropped to 3.5%

• F24 Payment restrictions: When settling the amounts via the F24 form within the 60 days, taxpayers are strictly prohibited from using any tax offsets/compensations (under Article 17 of Legislative Decree n. 241/1997) or formal instalment plans.
• If the Tax Authority updates and redetermines the outstanding amount based on clarifications provided by the taxpayer, a new 60-day deadline to benefit from the reduced sanctions starts from the receipt of the final communication.
• The automated calculation explicitly excludes any VAT credit resulting from the tax return of the year preceding the controlled period.
• The payment can be made by 31 December of the seventh year following the year in which the return should have been submitted, without prejudice to the ordinary assessment activity of the Tax Authorities.

Lithuania

VAT treatment of free transferred goods

Lithuanian State Tax Inspectorate (VMI) has published an updated version of its guidance on the VAT treatment of business gifts and goods provided free of charge. Released on 11 August 2026, the revised guidance reflects legislation in force from 1 January 2026.

The publication explains when goods transferred free of charge are subject to Value Added Tax (VAT) and sets out the circumstances in which exemptions may apply.

In principle, goods provided free of charge are treated as being consumed for the private purposes of the VAT payer. This can trigger a VAT liability.

The guidance confirms that this treatment generally applies to:

• Gifts provided to business partners
• Goods distributed free of charge to potential customers
• Free samples

Certain goods can be transferred without triggering VAT where they qualify as low-value gifts or research samples. This may apply where:

• The goods are consistent with the VAT payer’s normal business activities, including products they produce or intend to produce
• The goods are special samples of goods intended for distribution (pre-packaged in smaller quantities than these goods are usually packaged and packaging is clearly indicating that these are not intended for sale)
• The goods provide information about the VAT payer and/or his economic activity (branded)

The VMI guidance includes several examples of goods that may be treated as low-value gifts and therefore fall within the exception. These include:

• Food products distributed free of charge during promotional events
• Other promotional items provided to customers where the value of each item does not exceed €10
• Gifts with a value of up to €15 provided to customers who purchase specific goods or services
• Gifts provided to business partners with a value of up to €75 per person per occasion
• Prizes or gifts awarded to winners of competitions, lotteries, contests or similar events where the value does not exceed €75

The updated guidance provides practical clarification on when free transfers of goods are treated as taxable supplies and when exceptions may apply. Businesses using promotional goods, samples or customer incentives should review the value thresholds and conditions to ensure the correct VAT treatment is applied.

The Netherlands

The Netherlands confirms mandatory eInvoicing and eReporting from July 2031

The Netherlands has formally outlined its plans for mandatory eInvoicing and digital reporting, providing businesses with a clear implementation roadmap over the next five years.

In an outline letter submitted to Parliament, State Secretary for Finance, Eelco Eerenberg, confirmed that the Netherlands will align its approach with the European Union’s VAT in the Digital Age (ViDA) initiative.

Key implementation dates

The rollout will take place in three phases:

Date	Requirement
1 July 2030	Mandatory eInvoicing for all domestic business-to-business (B2B) transactions
1 July 2030	Mandatory eInvoicing and digital reporting for cross-border transactions in line with EU ViDA requirements
1 July 2031	Mandatory digital reporting for domestic B2B transactions

The Netherlands has confirmed that several current VAT invoicing exemptions will continue after the introduction of mandatory eInvoicing.

• The scheme for small businesses (KOR) – with a turnover of up to €20,000 per calendar year, are exempt from eInvoicing and eReporting. The exception for this group will continue to apply after July 2030.
• A few additional exceptions include:
  • Entrepreneurs who only carry out VAT-exempt services
  • Special invoicing obligations for, for example, resellers, travel agents, in respect of the supply of excise goods and mineral oils or in respect of public transport
  • Special rules for retailers and publishers of periodicals
  • Simplified invoices
  • Transactions where there is no invoicing obligation, including certain internal services and supplies provided free of charge

Other timelines relating to eInvoicing and eReporting to take note of:

• Autumn 2026: Starting internet consultation
• Until October 2026: Final decision between the Peppol Network (already mandatory in the Netherland) and the upcoming European Business Wallet (currently under development)
• Summer 2027: Submission of legislative proposal
• 1 July 2028: Target date for completion of the parliamentary process, allowing a two-year preparation period before implementation.

The government has indicated that this lead time is intended to support business readiness, system development and testing, while also allowing the Dutch Tax and Customs Administration to prepare for the new reporting regime.

What businesses should do now

Although the first compliance obligations do not take effect until 2030, the confirmation of the implementation timeline gives businesses greater certainty around future eInvoicing requirements. Companies operating in the Netherlands should monitor the upcoming consultation process and begin assessing how their invoicing systems will align with both Dutch requirements and the wider EU ViDA framework.

The Netherlands

Launch of digital VAT correspondence for businesses

The Dutch Tax Administration has introduced a new option that allows businesses to receive their VAT correspondence exclusively in digital format.

Announced on 8 September 2026, the initiative forms part of the Tax Administration’s wider digitalisation programme and will be rolled out in phases, beginning with VAT-related communications.

Detailed step-by-step guidance is available to help taxpayers switch from paper mail to digital correspondence through the Tax Administration’s online portal. The choice is voluntary, and taxpayers can revert to paper correspondence at any time if they prefer.

Romania

Free apps to validate SAF-T and VAT return data

Romania’s National Agency for Fiscal Administration (ANAF) has introduced two free applications designed to help taxpayers validate information before submitting their Standard Audit File for Tax (SAF-T) declaration.

The launch was announced through Notification ARPC No. 782, issued on 26 August 2026.

The applications can be installed and run locally on a taxpayer’s computer and are intended to support data quality and reduce reporting errors before submission.

• The first application validates the information declared by Form D406 SAF-T
• The second application compares and validates the information declared by D406 in the VAT Return (Form D300)

The applications will be tested between September and November 2026. ANAF wants to improve these tools together with users. Observations, proposals or notifications regarding possible errors can be sent to the following email address: saft@anaf.ro

Romania introduces automatic VAT assessments for missing VAT returns

Romania has introduced a new procedure allowing the tax authorities to automatically assess VAT liabilities when periodic VAT returns are not submitted.

The new rules were introduced by ANAF Order No. 1,022 of 20 August 2026, published in the Official Gazette and effective from 3 September 2026. The procedure applies to taxpayers that have failed to submit their periodic VAT return (Form D300) for tax periods beginning from July 2024 onwards.

The new framework is triggered when a taxpayer does not submit a required periodic VAT return. In these cases, the ANAF can determine the VAT due based on information already available in its records.

Step 1: Notification regarding the non-submission of VAT return

ANAF will first issue a notification informing the taxpayer that the VAT return has not been submitted. Following receipt of the notification:

• The taxpayer has 15 days to submit the missing VAT return.
• Failure to submit the return within this period may result in a fine and allows ANAF to proceed with an ex officio VAT assessment.
• The taxpayer must attend the tax office within five days of receiving the notice to exercise their right to be heard under Article 9 of the Fiscal Procedure Code.
• If the taxpayer formally declines to attend, the right to be heard is considered fulfilled through a written waiver.

Step 2: Second invitation to be heard

If a taxpayer:

• Does not submit the missing VAT return
• Does not attend the first hearing, and
• Has not submitted a written refusal

ANAF will issue a second invitation, granting a final five-day period to attend and present their position.

Step 3: Ex officio VAT assessment

If the VAT return remains unfiled, ANAF may issue a decision assessing the VAT due. The assessment is based on information available in the tax authority’s records, and VAT liabilities identified from transactions carried out during the relevant period.

Payment deadlines

The payment deadline depends on when the assessment decision is communicated:

• Communicated between the 1st and 15th of the month: Payment is due by the 5th of the following month
• Communicated between 16th and 31st of the month: Payment is due by the 20th of the following month

Taxpayers can have the ex officio assessment cancelled by submitting the missing Form D300 within 60 days of receiving the assessment decision. If the missing return is submitted within this period

• ANAF will process the return.
• The ex officio VAT assessment will be cancelled through a formal cancellation decision.

However, returns submitted after the 60-day deadline will not be processed under this procedure, and the amounts established through the ex officio assessment will remain payable.

Taxpayers may challenge the assessment decision within 45 days of receiving it. Failure to appeal within this period results in the loss of the right to challenge the decision.

Slovakia

Slovakia proposes to remove buyer eReporting from eInvoicing framework

Slovakia has proposed significant changes to its upcoming eInvoicing regime, including the removal of buyer-side reporting obligations from the first phase of implementation.

The changes are contained in Government Proposal 1454 (LP/2026/282), which has been submitted to the Slovak Parliament. The proposal restructures the rollout of mandatory eInvoicing into a phased programme running from 2027 to 2030.

While the mandatory issuance of eInvoices remains active for 1 January 2027, the proposal removes the immediate domestic reporting obligations for buyers.

The proposed timeline

Date	Requirement
1 January 2027	Mandatory issuance of eInvoices, and reporting from supplier to the tax authority
1 January 2027	The obligation of the customer to report data from the received e-invoice via a delivery service is to be deleted
1 January 2027 to 30 June 2027	A tolerance period is introduced, during which non-compliance with certain obligations in relation to mandatory eIvoicing and digital data reporting will not be sanctioned.

During the tolerance period, penalties would not be applied for certain breaches of the new eInvoicing and digital reporting obligations. However, the tolerance period would not apply to the obligation to receive electronic invoices. Businesses would still be required to ensure they can receive eInvoices through an approved delivery service and maintain the necessary digital infrastructure from the start of the mandate.

Later implementation phases

The revised roadmap includes two further milestones:

Date	Requirement
1 July 2028	Implementation of the EU e-commerce directive requirements
1 July 2030	Mandatory real-time reporting extended to cross-border EU transactions in line with the ViDA initiative

Transitional rules for invoice corrections

The proposal also includes specific rules for credit notes and debit notes issued during the transition period.

Between 1 January 2027 and 30 June 2030, businesses correcting invoices originally issued before the eInvoicing mandate took effect (before 31 December 2026) may continue to use the legacy invoice format.

The exception does not apply where the original document was already issued as an electronic invoice.

From 1 July 2030, all credit notes and debit notes will be required to be issued as structured electronic invoices.

What businesses should watch

While the proposal still requires mandatory eInvoicing and supplier reporting from January 2027, the removal of buyer reporting would reduce the initial compliance burden on businesses. Companies should continue monitoring the parliamentary process, as the proposed changes have not yet completed the legislative approval process.

UAE

UAE introduces new record-keeping requirements from 30 July 2026

The United Arab Emirates (UAE) has introduced new rules governing how businesses maintain accounting records and commercial books.

The requirements are set out in Federal Tax Authority (FTA) Decision No. 4, issued on 2 June 2026 and effective from 30 July 2026. The decision provides detailed standards for retaining documents in both electronic and paper formats.

Electronic and paper copies:

• The electronic copy or the photocopy must be an identical copy of the original document and must include all pages in the same order as the original document. Note: Partial scanning of any part of the document will not be accepted
• The details and data contained in the electronic copy must be clear and easily legible when displayed on a computer screen
• Paper copies must be produced using ink and paper of sufficient quality to prevent fading during the record-retention period.
• Black-and-white photocopies of colour documents are permitted, provided all information remains clearly legible.

Access requirements for the FTA

The FTA must be granted full access to all records and commercial books upon request:

• Where the electronic copies or system in which they are kept and protected by encryption or password, the person must provide the necessary encryption keys or password to enable access for the authority
• Access to photocopies must be available, including access to the locations where they are stored.

Use of third party record-keeping providers

Businesses may appoint a third party to maintain their accounting records and commercial books, provided that the person remains legally responsible for maintaining such records and books and ensuring their safety.

United Kingdom

United Kingdom updates VAT refund rules for non-UK businesses in VAT groups

HM Revenue & Customs (HMRC) has changed the way non-UK businesses that are members of a VAT group must submit UK VAT refund claims.

The change was announced through an update to VAT Notice 723A: Refunds of UK VAT for non-UK businesses and a related HMRC policy paper published on 8 September 2026.

For VAT refund claims covering periods from 1 July 2026, each non-UK VAT group member must submit its own VAT refund claim for UK VAT it has incurred. Claims submitted by the VAT group’s representative member will no longer be accepted unless that representative member incurred the VAT itself.

This change reverses the position introduced on 1 January 2021, under which all non-UK VAT group members were required to submit claims through the VAT group’s representative member. The previous approach created unintended consequences that prevented some businesses from obtaining refunds.

As a transitional measure, for the claim period from 1 July 2025 to 30 June 2026, for which the submission deadline is 31 December 2026, HMRC will accept claims from either the individual VAT group member that incurred the VAT or the representative member of the VAT group.

Upon request by the claimant, HMRC will review previous claims dating back to 2021 that were rejected because the representative member did not submit the claim. Requests to review such claims can be submitted by 31 August 2027. HMRC will not consider requests received after this date.

What businesses should do

Non-UK businesses that are members of a VAT group should review their VAT refund processes to ensure future claims are submitted by the entity that incurred the VAT. Businesses that had claims rejected under the previous rules may also wish to assess whether they are eligible to request a review.