In this article, the authors explain how the VAT treatment in China of donations to charities and supplies by charities to beneficiaries resembles that in traditional VAT systems with some important differences, particularly in respect of donations of goods to charities, that point to opportunities for reform.
The author in this article examines the evolution of Chile’s e-invoicing system from a VAT control mechanism into a broader digital infrastructure supporting automated compliance and regulatory oversight, as well as the impact that this system had on certain financing operations. He also considers its cross-border limitations and the lessons that the Chilean experience may offer for the implementation of VAT in the Digital Age in the European Union.
In its judgment of 11 February 2026 in Case T-689/24, I. S.A., the General Court ruled that the right of deduction comes into existence once the substantive conditions are satisfied, that is, when the tax becomes chargeable and the transaction has actually been carried out, and that a late invoice cannot be used as a device to push that right into a later period. Conditioning deductions on holding an invoice within the same tax period, even where the invoice is in hand before the VAT return is filed, is incompatible with articles 167, 168 and 178 of the VAT Directive and runs counter to the principles of neutrality and proportionality.
This article examines the rules for quantifying IBS (imposto sobre bens e serviços) and CBS (contribuição sobre bens e serviços), the taxes introduced by Brazil’s consumption tax reform to gradually replace a significant part of the current indirect taxation system. The analysis focuses on the taxable basis of the new taxes, their reference rates, standard rates and nationally uniform rates, as well as the differentiated, specific and special regimes set forth in Complementary Law No. 214/2025. Although the reform was originally based on the ideals of simplification, neutrality and uniformity in consumption taxation, its implementing legislation sought to preserve certain preferential treatments through rate reduction rules, deemed tax credits, sector-specific calculation rules and special regimes applicable to certain transactions, taxpayers and geographically incentivized areas.
E-invoicing and digital reporting are a worldwide trend. In this article, the author depicts the current state of play in Spain of legislation introducing mandatory e-invoicing and digital reporting of invoice content. The author explains the three pieces of legislation in Spain dealing with these digital trends, which have different levels of maturity. He concludes the analysis by offering self-produced conclusions and recommendations about the opportunities and challenges for Spain of the adoption of these three initiatives, highlighting the need to prevent overlapping of obligations and double reporting and the requirement for alignment with the ViDA package by July 2030.
In this Column, the author explains that Brazil’s indirect tax reform replaces a fragmented and outdated system of multiple federal, state and municipal consumption taxes with a dual VAT model consisting of the CBS (federal tax) and IBS (subnational tax), aiming to simplify and modernize the system.
Brazil’s new consumption tax depends as much on administrative design as on constitutional reform. Indeed, the tax on goods and services (imposto sobre bens e serviços, IBS) does not merely replace former taxes; it requires a permanent institutional framework capable of coordinating regulation, registration, invoicing, collection, payment, compliance, and dispute resolution across different levels of government. In that architecture, the IBS Management Committee (CGIBS), having received integrated functions in regulation, collection, revenue allocation, and administrative adjudication, is not a secondary institution but the operational centre of the new model. In this article, the author examines the crucial administrative dimension of the Brazilian VAT reform.
Over recent decades, VAT fraud has become one of the most persistent fiscal and administrative challenges in the European Union. It undermines the smooth functioning of the internal market, distorts fair competition, reduces Member States’ revenues, and erodes the European Union’s own financial resources. A particularly damaging form of this fraud in intra-Community trade is “carousel fraud”. The author analyses the main preventive and repressive measures adopted at the EU level to combat carousel fraud, drawing on legislation and the case law of the Court of Justice of the European Union (CJEU). It evaluates how well these measures achieve their intended purpose and highlights the continuing need for a coherent and uniformly applicable EU-wide approach. The author argues that, despite the significant efforts made, the current EU framework still lacks the necessary harmonization to effectively eliminate carousel fraud across the Member States.
Brazil’s Constitutional Amendment No. 132/2023 introduced a new dual consumption tax system based on the tax on goods and services (imposto sobre bens e serviços, IBS) and the contribution on goods and services (contribuição sobre bens e serviços, CBS). Although imposed by different levels of government, both taxes share the same substantive rules on taxable events, tax base, non-taxable events, special regimes, and non-cumulation. In this article, the authors examine the notion of taxable supply under the new model, focusing on the statutory treatment of goods and services, onerous and gratuitous transactions, imports and exports, and the main untaxable events, based on Complementary Law No. 214/2025 and its subsequent adjustments.
The author in this article examines the evolution and key features of Bolivia’s mandatory e-invoicing framework, implemented in 2021, analysing the legal basis, invoicing modalities, compliance mechanisms, sanctions and transition process, highlighting how real-time electronic invoicing has transformed VAT compliance.
In this article, the author addresses the challenges arising from the regulatory and technical foundations of structured e-invoicing and e-reporting, focusing on EN 16931, national mandates within the European Union, and the VAT in the Digital Age framework. He highlights that, for international operating companies, this environment poses significant strategic, operational, and architectural challenges. Selecting and implementing appropriate solutions requires not only legal alignment and technical compatibility, but also a long-term strategy for scalability, transparency, and functional control.
Portugal’s reduced VAT rate for urban redevelopment became a decade-long source of uncertainty and controversy due to fragmented municipal interpretations, shifting tax authority practices, and a recent unifying judgment of the Supreme Administrative Court triggering retroactive standard VAT rate assessments. In this article, the authors analyse this conflict through the lens of legitimate expectations, contrasting standards of the Court of Justice of European Union with Portuguese constitutional protections. The article highlights how transitional rules put in place by the national legislature were jeopardized by administrative and judicial practices and concludes with a broader inquiry concerning constitutional pluralism in VAT adjudication.
In this Column, the author argues that the European Union should prioritize a VAT omnibus to reduce administrative burdens and barriers in cross-border trade, especially for SMEs. She highlights three key reforms: ensuring technological neutrality in e-invoicing, aligning VAT with customs (and ultimately goods with services), and introducing favourable VAT rules for donations to support sustainability.
Since 1 January 2025, German taxable persons have had to issue e-invoices for domestic business-to-business (B2B) supplies. In this article, the author mentions that this is a first comprehensive step towards digital invoicing and automatic processes among German companies. Furthermore, the obligation of issuing e-invoices will lead to near-real-time reporting of individual transactions. The German e-invoicing project is a development parallel to those of various other EU Member States and to EU-level developments with the well-known VAT in the Digital Age reforms.
The authors in this article examine the treatment of low-value imports in cross-border e-commerce and the challenges these flows create for consumption tax collection. They discuss the European Union’s removal of the low-value import VAT exemption and its shift toward simplified collection mechanisms for low-value consignments. Then, they contrast this with Malaysia’s incremental approach, including the introduction of sales tax on low-value goods.
Indonesia’s 2021 VAT reform reclassified coal as a taxable good, aiming to align with global neutrality principles but inadvertently triggering a massive, sustained surge in VAT refunds. The author in this article examines the resulting fiscal shock by analysing the legal conflicts with existing Perjanjian Karya Pengusahaan Pertambangan Batubara (Coal Contracts of Work) and the economic mechanics of the sector’s inverted duty structure. Drawing on comparative jurisprudence, the author offers targeted policy recommendations to mitigate state revenue erosion while preserving the fundamental principles of VAT neutrality.
In this article, the author analyses the recent implementation of the VAT group regime in Portugal. Starting from a brief overview of the EU law provision that serves as a base at the national level – article 11 of the VAT Directive – it then delves into the main characteristics of the Portuguese implementation, unveiling how it differs from the former and the way in which it does not safeguard nor attain its main and intended goals. Critically, the author concludes that the measures’ limited advantages and strict requirements transform an otherwise domestic VAT landmark into a measure that almost completely defeats its purpose, risks infringing EU law and possesses questionable overall attractiveness.
The Italian Supreme Court issued two sentences supporting VAT deductibility on transactions costs related to merger leveraged buyout (MLBO) operations. The European Commission supported this position and pushed the Italian tax authorities to change their position. In this article, the author retraces the sequence of events leading to this important change and explains how and to what extent this change enables the concerned taxable persons to recover deductible VAT retroactively.
The VAT handling of tour operators from outside the European Union as regards their travel business activities in Germany was the subject of an article in 2021. Hans-Martin Grambeck, “Germany Excludes Travel Services Provided by Non-EU Companies from the Tour Operator Margin Scheme”, International VAT Monitor 32, 6 (2021): 297-302, https://doi.org/10.59403/wb3hpt. The core message was that non-EU tour operators were excluded from the Tour Operator Margin Scheme (TOMS) with a right to opt into TOMS according to a letter published by the German Ministry of Finance. Now – five years later – this topic deserves an update since, firstly, the transitional period may end by the end of 2026 whilst nobody knows yet what comes after that and, secondly, the position of the German tax administration has been challenged by a UK tour operator with the matter now pending in the German supreme court.
In this article, the author provides a systematic review of the value added tax (VAT) treatment of transfer pricing adjustments in intra-group transactions, focusing primarily on the recent Opinion of Advocate General Kokott in Stellantis Portugal, S.A. v. Autoridade Tributária e Aduaneira (C-603/24). Drawing on Court of Justice of the European Union (CJEU) case law, as well as analyses by the VAT Committee and the VAT Expert Group, the author looks at the evolution of the analytical framework applicable to TP adjustments, from interpretative guidance to recent judicial developments.
