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Each month we share a summary of 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.
EU publishes new regulations and updated guidance for ViDA single VAT registration
The European Commission has published legislation supporting the new Single VAT Registration (SVR) regime of the VAT in the Digital Age (ViDA) reforms.
Implementing Regulation (EU) 2026/1869 updates the operation of the EU’s VAT special schemes. These include the Union One-Stop Shop (OSS), non-Union OSS, Import OSS (IOSS) and the new Transfer of Own Goods (TOOG) scheme. The regulation does not create new VAT obligations. Instead, it standardises registration procedures, electronic reporting and VAT return formats to ensure consistent implementation across Member States. It supports both the expansion of the Union OSS from 1 January 2027 and the wider SVR reforms from 1 July 2028.
The European Commission has also published updated guidance on its SVR reforms. This confirms that, from 2027, only qualifying intra-EU distance sales dispatched from the supplier’s member state of establishment will count towards the €10k OSS threshold. The reforms also expand the role of the OSS, including reporting for certain transfers of own goods. This may reduce the need for businesses holding stock across the EU to maintain multiple VAT registrations. Further changes will affect online marketplaces, IOSS administration and the VAT treatment of cross-border energy supplies.
Key takeaways
Digital reporting requirements and e-invoicing tend to attract more attention, but they are not the only ViDA pillar that businesses need to familiarise themselves with.
Contact: Mike Palmer, RSM UK
United States (California): sales tax expanded to electronically delivered software and SaaS
California is significantly expanding its sales and use tax base from 1 January 2027. Under new legislation, prewritten computer software generally will be treated as taxable tangible personal property regardless of whether it is delivered on physical media, transferred electronically, or accessed remotely through a software-as-a-service (SaaS) model.
There are various exclusions (including e-books, music and streaming content), exemptions (custom software) and tax shift provisions (for certain large purchasers in specific circumstances). The new law also establishes that electronically delivered or remotely accessed software will generally be sourced based on the customer's location information. As a result, this will create significant compliance considerations for software vendors and multistate businesses. Further guidance and regulations are expected on how to allocate tax for enterprise software used across multiple jurisdictions and the documentation required to support sourcing methodologies.
Key takeaways
California's taxation of electronically delivered software and SaaS represents one of the most significant state sales tax changes of 2026. Businesses that sell, purchase, or license software should assess the impact on contracts, billing systems, exemption documentation, use tax processes and multistate sourcing methodologies before 1 January 2027. Several operational and administrative issues remain unresolved and taxpayers should continue to monitor forthcoming regulations and guidance.
Contact: Andrienne Albritton, RSM US
Three judgments from the European Court on business transfers
When A&P Deco sold its garden centre business, it retained the property and granted a new VAT-exempt lease to the purchaser. In the European Court’s judgment, this created a new property asset rather than transferring the existing property as part of a transfer of a going concern (TOGC).
This meant that A&P Deco suffered a Belgian input tax restriction.
In Peckeger, the transfer of let properties by the landlord to a company that he owned was found to qualify as a TOGC. This is despite Austrian legislation suggesting the transfer should be subject to VAT.
In Szytelbiecka, the court found that the donation of a single business to the donor’s two daughters did not qualify for TOGC treatment. This was because there were no distinct assets associated with each disposal that could separately be regarded as a going concern.
Key takeaways
These three cases illustrate the same key message: TOGC rules can be complex and can vary even within the EU. VAT advice should be sought as part of any business transfer to avoid unwelcome surprises.
Contact: Piotr Wyrwa, RSM Poland
India: increase in enforcement of GST obligations for non-established organisations
Organisations that provide certain electronic services to Indian consumers may have to account for GST at 18%. This includes businesses that are not registered for GST in India. While these rules have existed for several years, there has been a significant increase in the Indian tax authority’s enforcement of the regime following a Supreme Court decision in 2025. The OIDAR (Online Information and Database Access or Retrieval) rules can apply to a wide range of digital supplies including software, cloud services, digital content, data services and certain online gaming activities. There is no threshold so even a single sale might trigger a registration obligation.
Key takeaways
Businesses selling digital services to Indian customers should review whether their supplies fall within the OIDAR regime and take any necessary corrective action. Even if your core market is not B2C, it is possible that some of your customers are not GST-registered.
Contact: Siddharth Surana, RSM India
P-GmbH: European Court confirms scope of the tour operators’ margin scheme
P-GmbH & Co KG (P) organised ‘coffee trips’ (day trips around Germany to enjoy coffee and cake). During the trips, customers were encouraged to buy a variety of dietary supplements, medical devices and financial services. The profits from these sales meant that P charged less for the coffee trip than the transport costs it paid. Despite the business model adopted by P, which focused on sales made during the trips, the European Court has ruled that it must apply the tour operators’ margin scheme (TOMS). This meant it was not entitled to a credit for the VAT incurred on the transport costs, as the court confirmed there is no relief for a negative margin under TOMS.
Key takeaways
The TOMS regime is a highly complex area of law that leads to many VAT results that might appear counter-intuitive. Significant care should be taken by travel businesses affected by TOMS, along with any organisation arranging an event that might trigger compliance with this regime.
Contact: Heiko Klumpp, RSM Ebner Stolz
Brazil proposes 27.91% combined rate for new VAT system
Brazil has published a proposed 27.91% combined standard rate for its new dual VAT system, which is being phased in between 2026 and 2033. The indicative rate comprises a 9.21% federal contribution on goods and services (CBS) and 18.7% tax on goods and services (IBS), administered at state and municipal level. The 2027 transitional IBS rate remains 0.1%, divided equally between states and municipalities.
The reforms will ultimately replace four existing indirect taxes with the destination-based CBS and IBS. CBS becomes fully operational from 2027, while the transition to IBS will run from 2029 to 2032. Full implementation is scheduled for 2033.
Key takeaways
Businesses operating in Brazil should prepare for several years of disruption as the transition to a new, simpler, regime is implemented. It is important to keep abreast of the legacy and new tax requirements, which may run in parallel along with changes to e-invoicing and reporting.
Contact: Felipe Fortes, RSM Brazil
Global e-invoicing update
Governments continue to accelerate the shift towards structured e-invoicing and transaction-level VAT reporting, with several important developments during August and September.
- France: Mandatory e-invoicing and e-reporting went live on 1 September 2026. Large and intermediate-sized businesses must now issue domestic B2B e-invoices and undertake relevant e-reporting, while all French-established businesses must be able to receive e-invoices. SMEs must issue French e-invoices from September 2027.
- Greece: enters the second and final phase of mandatory B2B e-invoicing on 12 October 2026, extending the obligation to virtually all remaining resident businesses. Taxpayers must notify the Greek tax authorities by 30 September whether they will use a certified provider or the free government invoicing tools.
- Luxembourg: Draft regulations for the proposed 2028 B2B mandate confirm Peppol as the preferred exchange network, with MyGuichet.lu providing transitional and fallback options.
- Slovakia: New guidance has been issued ahead of the January 2027 B2B and B2G e-invoicing mandate. Slovakia is adopting a decentralised five-corner Peppol model, with a soft landing for penalties until March 2027.
- Hungary: eVAT digital VAT reporting becomes mandatory from January 2027, replacing the existing ÁNYK VAT return filing process.
- Oman: has officially delayed its main mandate until 1 April 2027, while commencing a pilot phase for its largest taxpayers from August 2026. The Peppol-based five-corner model will include both B2B e-invoicing and B2C e-reporting.
- Brazil has published the first official implementation timetable for the IBS/CBS e-invoicing reforms. Phased deployment will run from 3 August 2026 through 1 January 2027 across electronic fiscal documents, service invoices, digital platforms and import reporting.
- Vietnam: has modernised its e-invoicing framework from 1 July 2026, introducing optional e-invoicing for non-resident businesses, potentially improving VAT recovery opportunities for foreign suppliers.
- South Africa: the South African Revenue Service is consulting on a Peppol-based e-invoicing and near real-time reporting model, targeting phased implementation from 2030.
Contact: Christian Balk, RSM UK
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).
