International Indirect Tax Update | September 2026

Each month we share a summary of key global indirect tax news to raise awareness of developments in key economies.

If you think any of these updates may affect you, please contact your usual RSM adviser or the relevant local indirect tax contact.
 
 

GERMANY SIGNALS DIGITAL VAT ENFORCEMENT STRATEGY

Germany has unveiled a new action plan to strengthen tax enforcement through artificial intelligence, centralised tax data and real-time VAT reporting. The proposals include a national data analysis platform that will combine information from federal and state tax authorities, allowing AI tools to identify suspicious transaction patterns and VAT fraud more effectively.

The action plan also commits to introducing real-time VAT transaction reporting. The proposals, together with Germany’s phased B2B e-invoicing mandate, suggest the country may be laying the foundations for domestic VAT e-reporting. This follows an emerging European approach already seen in Belgium and under consideration in the Netherlands.

Additional measures include longer tax record retention, mirror servers for non-EU businesses storing tax data, mandatory registered cash systems in high-risk sectors and stronger enforcement powers targeting organised tax fraud.

What it means
German businesses should assess enterprise resource planning (ERP) systems and invoicing readiness for real-time VAT reporting. Strengthening data governance in preparation for increased AI-driven tax authority scrutiny and fraud detection should also be a priority.

Contact:  Heiko.Klumpp@ebnerstolz.de, RSM Ebner Stolz
 

GIBRALTAR INTRODUCES 15% TRANSACTION TAX ON GOODS

Gibraltar has introduced a new 15% transaction tax on imported and locally-manufactured goods from 15 July 2026, marking a significant change to its long-standing VAT-free regime. The rate will increase to 16% in 2027 and 17% in 2028, with reduced, zero and exempt rates applying to selected goods and sectors.

The measure forms part of the landmark UK-Spain agreement that secures continued open border arrangements between Gibraltar and Spain following Brexit. Businesses will continue to benefit from frictionless movement of people and goods, while qualifying UK-origin goods remain outside the scope of the new tax.

What it means
Although not a VAT, the transaction tax functions as a broad-based indirect tax on goods and aligns Gibraltar more closely with EU fiscal practice. The reform illustrates how indirect tax policy is increasingly being used to support wider trade and economic objectives. Affected businesses should consider the impact.

Contact: Andy.Ilsley@rsmuk.com, RSM UK
 

POLAND AND PORTUGAL ADVANCE PRE-FILLED VAT RETURNS

Poland and Portugal have announced further steps towards automated VAT compliance, using data collected through their digital reporting systems to generate pre-filled VAT returns. Both initiatives evidence the European (and indeed global) trend where tax authorities seek to reduce compliance burdens by reusing e-invoicing and transaction data already submitted by businesses.

POLAND EXPLORES KSEF-BASED VAT RETURNS

Poland’s Ministry of Finance is considering using transaction data collected through the mandatory KSeF e-invoicing platform to automatically prepare VAT returns and JPK_V7 filings. The proposal reflects the growing availability of real-time invoice data. However, tax specialists have noted that invoice information alone cannot capture the commercial context needed for accurate VAT reporting, including partial exemption, reverse charge rules and other adjustments.

PORTUGAL EXPANDS PRE-FILLED RETURNS

Portugal has confirmed a significant redesign of its periodic VAT return from July 2027. New transaction classifications, VAT rate breakdowns and additional reporting fields are intended to improve the quality of pre-filled returns generated from SAF-T invoice data. The reforms also support Portugal’s new VAT Group regime by enabling the tax authority to prepare consolidated draft returns.

Contact: Filipa Azevedo, RSM Portugal | Piotr.Wyrwa@rsmpoland.pl, RSM Poland
 

EU: IS THE APPLICATION OF COST-SHARING EXEMPTION BY AUSTRIAN BANKS STATE AID?

In 2017, the Court of Justice of the European Union (CJEU) ruled that the cost-sharing exemption (CSE) could not apply to financial services. This judgement dashed the hope of Austrian financial institutions that the CSE might provide the benefits of VAT grouping to cross-border services between affiliated companies. Austria was slow to react: until it was withdrawn last year, the CSE continued to be applied by banks, insurers and pension funds to all sorts of intra-group services (IT, consultancy, catering and childcare).

In the recent case of Schoger II EUR-Lex - 62025CN0360 - EN - EUR-Lex, the CJEU has ruled that the continued application of the CSE was a form of state aid. In its judgement:

• The Austrian CSE did not correctly reflect the Principal VAT Directive and was therefore a state measure. By reducing VAT revenues, it represented a use of state resources. 
• The exemption conferred a selective advantage for Austrian taxpayers. In this respect, it was irrelevant that the CSE impacted Schoger’s ability to recover VAT on its costs. The absence of output tax (under the reverse charge) conferred the possibility of a selective advantage. 
• The Austrian CSE was likely to distort competition and affect intra-EU trade

The CJEU also ruled that its judgement should be applied to past transactions as well as future ones. There was recognition that some tax periods may have been definitively closed.

What it means

• The CSE was not the only ground of appeal before the Austrian court. Schoger’s case related to the provision of ATM machines. It is possible that the bank was seeking to apply the exemption for payment handling services, distinguishing earlier cases such as Cardpoint.
• The judgement makes only passing references to the consequences of a state aid ruling when considering the time limitation request. The question then arises as to what defences against assessments might be available to Austrian banks, given the clear wording of Austrian law.
• The existence of state aid would have significant consequences for its banking and insurance sectors. VAT exempt transactions would have to be revalued, which could lead to vast numbers of appeals being lodged by financial services organisations with activities in Austria that had applied the CSE in good faith.  

Contact: Kristina.Babuder-Hummel@rsm.at, RSM Austria

If you would like more information on these topics or need assistance with VAT matters, you can contact the RSM Belgium VAT team at (vat@rsmbelgium.be).