Global VAT Guide: September 2026

The September 2026 edition of the Global VAT Guide brings together key VAT developments across Belgium, Brazil, Czech Republic, France, Hungary, Italy, Japan, Luxembourg, Oman, Portugal and Sri Lanka.

This month’s update shows continued acceleration of digital VAT transformation, with several jurisdictions moving from policy design into concrete implementation. eInvoicing, near real-time reporting, automated validation and tax authority access to transactional data are no longer isolated initiatives; they are becoming part of a broader move towards continuous digital compliance.

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

Belgium

Draft regulation of eReporting mandate for 2028

Belgium is continuing its digital VAT transformation. The Belgian Council of Ministers has formally approved a preliminary draft law that introduces a mandatory electronic reporting obligation for invoicing data, scheduled to take effect on 1 January 2028.

This follows the introduction of a general requirement for taxable persons to issue structured electronic invoices, which has applied since 1 January 2026. As an extension of this obligation, the preliminary draft provides for a form of electronic declaration “in near real time” of certain mandatory data appearing on invoices to the administration, both by the supplier or service provider and by its co-contractor.

The new reporting obligation is expected to reduce administrative requirements elsewhere. In particular, Belgium may abolish the annual list of taxable customers for businesses that are subject to the electronic reporting regime.

The measure included in the preliminary draft applies only to domestic transactions between two VAT-registered Belgian companies. For cross-border intra-Community transactions, the reporting framework will subsequently adapt to the European Union’s VAT in the Digital Age (ViDA) package, which Belgium is scheduled to integrate into national legislation by 1 July 2030 at the latest.

The draft law has been sent to the Data Protection Authority and the Council of State for review and opinion before it progresses.

Belgium restores the seven-year VAT retention and fraud limitation periods

Belgium has reversed part of its 2023 changes to VAT limitation and record-keeping rules, reducing both the VAT document retention period and the statute of limitations for VAT fraud cases from 10 years back to seven years.

The original changes, approved by the Belgian Parliament in November 2022 and effective from 1 January 2023, extended several VAT limitation periods. These included:

• Four years where a VAT return is filed late or not filed (previously three years)
• Six years for certain semi-complex tax returns
• Ten years for complex tax returns
• Ten years in cases of VAT fraud (extended from seven years)
• Ten years for retaining accounting records, invoices, and other supporting documents (extended from seven years)
• The objection period was extended from six months to one year

No changes were made to the standard three-year limitation period where VAT returns are filed on time.

Under Circular 2026/C/74, Belgium has now instated the previous seven-year periods for:

• The retention of accounting records, invoices and other VAT-related documents
• The statute of limitations in cases involving VAT fraud

Importantly, both the 2023 extension and the 2026 reduction apply to VAT that became due on or after 1 January 2023. For businesses operating in Belgium, this change reduces the length of time VAT records must be retained and shortens the period during which the tax authorities can pursue VAT fraud cases from ten years to seven years.

Belgium

Proposed increase of VAT exemption threshold could rise to €37,000 by 2031

Belgium is considering a significant increase to its VAT exemption threshold for small businesses, with proposals that could raise the limit from the current €25,000 to €37,000 by 2031.

On 15 June 2026, a draft bill was submitted to the Belgian Chamber of Representatives proposing a gradual increase in the threshold over five years. The original proposal would have increased the threshold from €25,000 to €30,000 by 2031 through annual €1,000 increases starting in 2027.

However, amendments proposed on 1 July 2026 introduced a more ambitious approach. Lawmakers noted that the current €25,000 threshold has remained unchanged since 2016 and no longer reflects inflation. As a result, they proposed a larger increase from 2027, followed by annual €1,000 increments until 2031.

If adopted, the VAT exemption threshold would increase as follows:

• €33,000 from 2027
• €34,000 from 2028
• €35,000 from 2029
• €36,000 from 2030
• €37,000 from 2031

The proposal remains under consideration as part of the legislative process. If approved, the new thresholds would take effect from 1 January 2027.

For small businesses operating under Belgium’s VAT exemption regime, the changes would allow more businesses to remain outside the scope of VAT registration and reporting requirements as turnover thresholds increase over time.

Brazil

Dual VAT rollout and eInvoicing deadlines

The Brazil government is implementing a two-step tax reform roadmap during 2026. They are separating the migration to its new eInvoicing platform from the activation of two new indirect taxes: the Contribution on Goods and Services (CBS) and Tax on Goods and Services (IBS).

Implementation of the National NFS-e portal

The migration to Brazil’s national electronic services invoice platform (National NFS-e Portal) will follow a phased approach:

• August to October 2026: Large and medium sized businesses will migrate in stages in order to adapt their ERP systems to the new technical layouts.
• 1 November 2026: Mandatory migration of micro and small companies. This deadline was postponed from 1 September 2026.
• 1 January 2027: Full adoption and mandatory technical compliance become obligatory for all taxpayers across the country.

CBS and IBS validation rules

Brazilian tax authorities have also confirmed a transition period for the new CBS and IBS tax fields on tax documents:

• Until 31 December 2026: According to the Tax Authority (RFB) and CGIBS, tax documents will not be rejected in the absence of CBS and IBS fields during the flexibility period.
• From 01 January 2027: The new taxes officially enter into force. Full legislative rules and validation requirements related to CBS and IBS become strictly applicable.

Businesses operating in Brazil should prepare for both the technical migration to the National NFS-e Portal and the introduction of the new CBS and IBS reporting requirements, as full compliance will be required from the start of 2027.

Czech Republic

Changes to VAT refund claims for Non-EU businesses from 2026

The Czech Tax Administration has announced several changes to its VAT refund procedure for businesses established outside the EU that are eligible to claim refunds under reciprocity agreements.

The new rules apply to VAT incurred on invoices issued from 1 January 2026 and are designed to simplify the refund process.

Key changes from 1 January 2026

For VAT incurred on invoices issued from 1 January 2026:

• Refund claims must be submitted using the new Form 5573-1
• Claims can be submitted electronically
• The filing deadline has been extended by six months to 31 December of year N+1 (for example, claims relating to 2026 invoices can be submitted until 31 December 2027)
• Copies of invoices are sufficient and original invoices are no longer required
• Applicants must provide an email address for correspondence
• A new postal address has been introduced for submitting refund claims to the Czech Tax Authority

Previous rules remain in place for earlier invoices

The previous rules continue to apply to VAT incurred on invoices issued up to 31 December 2025:

• Claims must be submitted on Form 5247-3
• The filing deadline remains 30 June year N+1
• Original invoices must accompany the claim

Certificate of VAT Status

The new rules do not clarify whether the Certificate of VAT Status should be submitted in original form or whether a copy is acceptable. As no specific change has been announced, it is currently presumed that the existing practice regarding this document remains unchanged.

Countries covered by reciprocity agreements

• Bosnia and Herzegovina
• Norway
• United Kingdom
• Switzerland

These changes should make the refund process more accessible for eligible non-EU businesses, particularly through electronic filing and the removal of the requirement to submit original invoices.

France

Extension of the tax document retention period to ten years

France has extended the period for retaining tax and accounting records from six years to 10 years.

The change was introduced by Article 36 of Law No. 2026-534 of 25 June 2026, which amends Article L.102 B of the French Tax Procedures Code (Livre des procédures fiscales). The new retention period applies to accounting books, records, invoices and supporting tax documentation.

Under the revised rules, businesses must now keep these documents for ten years instead of six.

The extension applies to documents and records whose retention period expires after 1 January 2027. In practical terms, this includes invoices issued from 1 January 2021 onwards.

Businesses operating in France should review their document retention policies and archiving processes to ensure they can meet the longer record-keeping requirement.

Official launch of nationwide eInvoicing framework in France

The French Ministry of Economy and Finance has formally announced the live rollout of the national eInvoicing framework, effective 1 September 2026. The launch follows guidance issued by the General Directorate of Public Finances (DGFiP) and has been formally enacted through Decree No. 2026-677, which completes the regulatory framework and aligns existing tax legislation with the new digital reporting environment.

From 1 September 2026

• All businesses must be able to receive electronic invoices through an approved invoicing platform.
• Businesses that have not yet selected a platform are expected to do so as soon as possible, either directly through a certified platform or via an existing provider such as accounting software, management software, a chartered accountant, a bank or another service provider.
• Large companies and intermediate-sized enterprises must begin issuing electronic invoices and transmitting invoice and payment data to the tax authorities in the required digital format.

From 1 September 2027

• Micro-enterprises, very small enterprises (VSEs) and small and medium-sized enterprises (SMEs) must begin issuing electronic invoices.

During the start-up phase, there will be no application of sanctions to companies encountering difficulties in the implementation of the reform. This administrative tolerance phase will continue through the end of 2026.

Hungary

Hungary announces replacement of ANYK tax filing system from 2027

Hungary’s National Tax and Customs Administration (NAV) has announced plans to retire its long-standing General Form Filling Framework Programme (ÁNYK) and replace it with modern digital alternatives from 2027.

To support the transition, NAV has launched a centralised knowledge base containing key information about the change. Available through the ÁNYK transition section on the NAV website, the resource is tailored to different user groups and explains the alternative filing options available for meeting tax reporting and submission requirements.

The transition will affect all taxpayer categories, including small businesses, large companies, accountants and software developers. NAV is encouraging taxpayers to begin preparing early to avoid disruption to tax filing, reporting and document submission processes once ÁNYK is decommissioned.

Key developments include:

• The ÁNYK system will be fully withdrawn from use and replaced by new digital reporting platforms from 2027.
• All users will need to transition to an alternative solution to continue meeting their tax compliance obligations.
• The new knowledge base organises guidance by taxpayer type, helping users identify the most suitable platform or filing method for their circumstances.
• To support fully automated, paperless reporting processes, NAV has accelerated development of its Machine-to-Machine (M2M) reporting framework. Version 4.0 of the Document API, known as BizonylatAPI, was released on 31 July, one month earlier than originally planned.

NAV has also introduced a dedicated support channel to help taxpayers manage the transition. A live FAQ section is available online, and technical or workflow-related queries can be submitted to anykkivaltas@nav.gov.hu.

With the 2027 deadline approaching, businesses using ÁNYK should review the available alternatives and begin planning for the move to NAV’s new digital reporting environment.

Hungary

Hungary introduces mandatory electronic receipt reporting

Hungary has launched a new electronic receipt reporting regime, with mandatory reporting requirements taking effect from 1 September 2026. The new rules apply to both manually issued receipts and computer-generated receipts.

Under the new system, businesses must submit receipt transaction data to the National Tax and Customs Administration (NAV) within three calendar days of issuing the receipt. The data must be reported in aggregated daily totals and broken down by the applicable VAT rate.

Four reporting options available

To support businesses with compliance, NAV offers several reporting methods:

• Cash register applications: Businesses can use a cash register application that automatically transmits receipt data to NAV, removing the need for separate reporting.
• eCash Machine app: Smaller businesses can use NAV’s free mobile cash register application, available since July 2025. The app runs on smartphones and automatically sends the required data to NAV.
• KOBAK web portal: Businesses that continue to issue traditional or computer-generated receipts can manually submit their daily summary data through the central KOBAK online portal.
• Machine-to-machine (M2M) API interface: High-volume businesses, online retailers and larger organisations can connect their internal systems directly to NAV and automate the transmission of transaction data.

Four-month grace period before penalties apply

To help businesses prepare for the new requirements, Hungary has introduced a four-month grace period running from 1 September to 31 December 2026.

During this period, businesses can choose and implement their preferred reporting method without facing penalties for non-compliance. Tax authorities have confirmed that audit activity will focus on technical support and guidance rather than enforcement.

From 1 January 2027, penalties may apply where receipt data reporting obligations are not met or where submitted information is incomplete or incorrect.

Businesses issuing receipts in Hungary should use the grace period to assess the available reporting options, implement the most suitable solution and ensure they are ready for full compliance before enforcement begins in 2027.

Italy

VAT deduction period extended from one year to two

Italy has introduced a significant change to its VAT recovery rules, giving businesses more time to claim input VAT on their purchases.

Under Legislative Decree No. 148 of 7 August 2026, published in the Official Gazette on 11 August 2026 and effective from 12 August 2026, the deadline for exercising the right to deduct input VAT has been extended from one year to two years following the year in which the deduction right arises.

What has changed?

Before the amendment, businesses had to exercise their VAT deduction right by the deadline for submitting the annual VAT return relating to the year in which the deduction right arose. Purchase invoices also had to be recorded by the filing deadline for the VAT return covering the year the invoice was received and attributed to that same year.

Under the new rules, businesses can now claim input VAT up to the deadline for submitting the annual VAT return for the second year following the year in which the deduction right arose.

The same extended timeframe applies to recording purchase invoices. Businesses may record invoices up to the deadline for filing the VAT return relating to the second year following the year of receipt of the invoice.

Why it matters

The reform gives businesses greater flexibility when managing VAT recovery, particularly where invoices are received late or where missed deduction opportunities are identified after the original VAT return has been submitted.

By extending the recovery window from one year to two years, Italy has reduced the risk of businesses losing VAT deduction rights because of administrative delays. The change also supports the government’s wider objective of simplifying tax compliance and reducing administrative burdens for taxpayers.

Italy

Special VAT refund relief for non-EU Businesses at the 2027 America’s Cup

Italy has introduced a temporary VAT refund measure to support businesses involved in the 38th America’s Cup, which will take place in Naples in 2027. It will be the first time the prestigious sailing competition has been hosted in Italy.

Under Decree-Law No. 108 of 26 June 2026, non-EU businesses participating in activities directly connected to the event may be eligible to claim refunds of Italian VAT, even if their country of establishment does not have a VAT reciprocity agreement with Italy.

Under Italy’s standard VAT rules, businesses established outside the EU can generally recover Italian VAT only where a reciprocity agreement exists between Italy and the claimant’s home country.

The new measure creates a temporary exception to that requirement. It applies to non-EU businesses that do not have a permanent establishment in Italy and incur Italian VAT on purchases or imports of goods and services directly linked to the organisation and delivery of the America’s Cup Naples 2027.

The relief is expected to reduce VAT costs for a wide range of participants, including racing teams, sponsors and service providers from non-EU jurisdictions. The measure forms part of Italy’s preparations for hosting one of the world’s leading international sporting events.

Japan

Japan extends transitional relief for non-qualified invoices

Japan has announced changes to the deductibility rules for non-qualified invoices as part of its 2026 tax reform. The National Tax Agency (NTA) published the changes on 1 April 2026, introducing a revised deduction schedule and extending the transitional relief period until 30 September 2031.

Under Japan’s invoice system, businesses can currently claim a partial deduction on purchases supported by non-qualified invoices. Previously, the deductible percentage was set at 80% until 30 September 2026, before dropping to 50% until 30 September 2029.

The revised rules introduce a more gradual reduction in deductibility after September 2026:

• 1 October 2026 to 30 September 2028: 70% deductible
• 1 October 2028 to 30 September 2030: 50% deductible
• 1 October 2030 to 30 September 2031: 30% deductible
• From 1 October 2031: No deduction permitted

Lower threshold for applying the deduction

Alongside the revised deduction rates, Japan is significantly reducing the threshold that limits access to this transitional relief.

Under the new rules, the partial deduction cannot be applied where the total value of taxable purchases (including tax) from parties that are not qualified invoice issuers exceeds ¥100 million (approximately €538,761, based on the OANDA exchange rate referenced by the NTA) during the relevant year or business year.

This threshold was previously set at ¥1 billion (approximately €5.39 million).

Where the ¥100 million threshold is exceeded, the deduction cannot be applied to the portion of taxable purchases above that amount.

The changes give businesses additional time to adapt to Japan’s qualified invoice regime. However, the phased reduction in deductibility and the substantially lower threshold may increase the impact on businesses that continue to transact with suppliers that do not issue qualified invoices.

Luxembourg

Draft law sets out roadmap for mandatory B2B eInvoicing

Luxembourg has taken a major step towards mandatory B2B eInvoicing. On 30 July 2026, Finance Minister Gilles Roth submitted Draft Law No. 8815, following government approval on 17 July 2026.

The proposed legislation would extend electronic invoicing requirements to domestic B2B transactions and establish a phased implementation timetable for businesses operating in Luxembourg.

Key implementation dates

If adopted, the new rules will be introduced in stages:

• 1 January 2028: All Luxembourg companies must be able to receive and process electronic invoices.
• 1 July 2028: Large and medium-sized companies must issue and transmit electronic invoices for domestic B2B transactions.
• 1 January 2029: Mandatory electronic invoice issuance and transmission will apply to all companies.

Technical framework

The draft law proposes using the Peppol network, which is already widely used for electronic document exchange, as the primary infrastructure for eInvoicing. Alternative solutions may also be permitted for issuing, transmitting and receiving electronic invoices, provided certain conditions are met.

Preparing for ViDA

The proposal is designed to help Luxembourg businesses prepare for the European Union’s ViDA reforms, which entered into force on 14 April 2025.

ViDA will introduce mandatory eInvoicing and digital near real-time reporting for cross-border transactions across the EU. Member States must implement these requirements by 1 July 2030.

By introducing domestic B2B eInvoicing ahead of the EU deadline, Luxembourg aims to give businesses more time to adapt their processes and systems before the wider ViDA requirements take effect.

Oman

New eInvoicing timeline confirmed as mandatory rollout begins in 2027

Oman has formally established the legal framework for electronic invoicing through Decision No. 189/2026, marking a significant milestone in the country’s digital tax transformation.

The decision follows the launch of the voluntary Fawtara pilot programme for 100 selected taxpayers and amends the VAT Executive Regulations to introduce Oman’s first legally binding eInvoicing requirements. It also replaces the previously announced four-phase implementation plan with a simplified two-phase rollout based on annual turnover.

New implementation timeline

The mandatory eInvoicing programme will now be introduced in two stages:

• Phase 1 (1 April 2027): Mandatory compliance for VAT-registered businesses with annual supplies exceeding OMR 5 million.
• Phase 2 (1 October 2027): Mandatory compliance for all remaining VAT-registered businesses, including small and medium-sized enterprises (SMEs), with annual supplies below OMR 5 million.

New legal requirement for eInvoicing

Decision No. 189/2026 amends Article 143 of the Executive Regulations of the VAT Law and introduces specific requirements for issuing electronic tax invoices.

Under the new rules, taxpayers must issue tax invoices in an approved and secure electronic format within 15 days of:

• Making a taxable supply, including supplies to non-taxable persons or to taxable persons using the goods or services for their own purposes.
• Making a deemed supply.
• Receiving payment, in full or in part, before the date of supply.
• Any other circumstances specified in the VAT Executive Regulations.

Temporary exemption available

Businesses may apply for a temporary exemption from the eInvoicing requirements by submitting a request to the Chairman of the Oman Tax Authority together with the required supporting documentation.

To maintain the exemption, taxpayers must continue to:

• Submit VAT returns within the statutory deadlines and in the format prescribed by the regulations.
• Pay VAT due within the deadlines set out in the law.

Why it matters

The new framework provides businesses with greater certainty around Oman’s eInvoicing requirements and significantly shortens the implementation timetable. With the first mandatory phase beginning in April 2027, businesses within scope should start assessing their invoicing systems and processes early to ensure they can meet the new digital reporting requirements when they take effect.

Portugal

New guidance on invoice corrections and VAT adjustments

The Portuguese Tax Authority has issued new guidance on how businesses should correct invoices, cancel invoices and make VAT adjustments.

Published on 28 July 2026, Circular Letter No. 25120 replaces the long-standing Circular Letter No. 33129/1993. The updated guidance reflects recent legislative changes, developments in digital invoicing and relevant court decisions.

Clearer rules for invoice corrections and cancellations

The Circular provides greater clarity on the differences between:

• Invoice corrections
• Invoice cancellations
• VAT regularisation procedures

As a general rule, businesses should use credit notes or debit notes when correcting invoices that affect the taxable amount or the VAT charged.

However, where an invoice contains a formal error that does not affect either the taxable amount or the VAT due, the incorrect invoice should generally be cancelled and replaced with a corrected invoice. In these cases, the Tax Authority states that a credit note should not normally be used.

Guidance on VAT errors and correction periods

A significant part of the new guidance focuses on errors of law, such as the incorrect application of:

• VAT rates
• VAT exemptions
• Reverse charge rules

The Circular confirms that VAT adjustments in favour of the taxpayer arising from these types of errors can generally be made within a four-year limitation period.

The updated guidance is intended to align invoice correction and VAT adjustment procedures with Portugal’s evolving digital invoicing framework while providing businesses with clearer rules on how and when corrections should be made.

Portugal

Updated VAT return forms introduce new reporting requirements

Portugal has published Portaria n.º 298/2026/1, introducing changes to the official VAT Periodic Return (Declaração Periódica do IVA), Annex R and the adjustment annexes linked to Boxes 40 and 41.

The updates affect how businesses report certain VAT transactions and will be introduced in two phases, with changes taking effect from 1 July 2026 and 1 July 2027.

Changes from 1 July 2026
The first phase focuses on VAT grouping and adjustments linked to reduced VAT rates.

Key changes include:

• VAT grouping regime: Box 01 will include a pre-populated selectable field to identify transactions falling under Portugal’s new VAT grouping framework. Individual net tax calculation fields (Boxes 93, 94, 95 and 96) will no longer be required.
• Reduced rate adjustments: The annexes for Boxes 40 and 41 will include new fields for reporting VAT adjustments relating to qualifying housing infrastructure and construction works that benefit from reduced VAT rates.

Changes from 1 July 2027

Key updates include:

• More detailed deductible VAT reporting: Box 24 in Table 06 will be replaced by Boxes 27, 28 and 29, allowing deductible VAT on other goods and services to be reported separately by VAT rate.
• New transaction categories: Additional reporting lines will be introduced for:
  • e-Taxfree transactions
  • Reverse charge electricity acquisitions from self-consumers
  • Special margin scheme transactions
• Expanded output transaction reporting: New Tables 06B, 06C and 06D will require more detailed reporting of taxable supplies, deemed supplies and non-turnover transactions by VAT rate.
• Updates to Annexes 40 and 41: References relating to clerical errors under Article 78(6) will be removed. A new section, Box 1-H, together with additional reporting lines, will be introduced to capture:
  • Approved bad debt relief adjustments
  • Corrections relating to errors of law
  • Tourist tax-free scheme adjustments

What businesses should do

These changes will require businesses operating in Portugal to review their VAT reporting processes and ensure that accounting and tax systems can capture and report the additional information required by the updated forms.

The revised reporting framework is intended to help the Portuguese Tax and Customs Authority collect more detailed transaction data while supporting the country’s evolving VAT compliance requirements, including the introduction of VAT grouping and enhanced transaction-level reporting.

Sri Lanka

New invoice requirements postponed until 1 October 2026

Sri Lanka has postponed the implementation of its new invoice requirements for a fourth time, giving businesses additional time to prepare for the updated invoicing format.

The Inland Revenue Department has confirmed that the new requirements will now take effect on 1 October 2026, according to Extraordinary Gazette No. 2500/106 published on 6 August 2026.

The revised rules were originally due to come into force in January 2026, before being successively postponed to 1 April 2026, 1 July 2026 and now 1 October 2026.

What is changing?

The new rules introduce more detailed specifications for existing invoice fields and add several new mandatory data requirements.

Key changes include:

• A prescribed invoice number format that businesses must follow.
• The total consideration must be shown both as a numerical value and written out in words.
• A telephone number must be included for both the supplier and the customer.
• The place of supply and the method of payment must be stated on the invoice.
• Each mandatory data element must be reported in a dedicated field within the invoice layout.

What businesses should do

Although the implementation date has been delayed, businesses should use the additional preparation time to review their invoicing processes and systems. Invoice templates may need to be updated to ensure all mandatory fields are captured correctly ahead of the new go-live date.

The repeated postponements provide more time for preparation, but businesses operating in Sri Lanka should continue planning for compliance with the revised invoicing requirements from 1 October 2026.