BDO Indirect Tax News

Introduction

Our April issue opens with the latest trade and tariff developments. The EU-US trade deal has cleared the EU Parliament and now moves into interinstitutional negotiations with the Council of the EU. We examine the implications of the US Supreme Court decision striking down President Trump’s IEEPA tariffs, with particular focus on what this means for affected businesses, including the potential for duty refunds and the procedural steps companies may need to take. We also assess the impact of the decision on Australian businesses that export to or operate in the US. 

E-invoicing continues to dominate compliance agendas worldwide:

• Four African countries—Botswana, Gabon, Nigeria and The Gambia—are transitioning to e-invoicing. 
  • Mandatory e-invoicing applies in Botswana as from April 2026 for VAT-registered businesses. 
  • The new e-invoicing system in Gabon requires taxpayers to issue e-invoices to deduct input VAT.
  • Nigeria is preparing to roll out an e-invoicing system for taxpayers with turnover of NGN 5 billion or more. 
  • The Gambia is planning an e-invoicing system for VAT-registered taxpayers but no implementation timeline has been announced. 
• The criteria for large corporates falling within the scope of the first phase of Ireland’s implementation of the ViDA e-invoicing and reporting obligations will be required to issue e-invoices starting on 1 November 2028.
• Singapore is accelerating tax digitisation through GST InvoiceNow, which will require GST-registered businesses to transmit invoice data directly to the tax authorities.
• A recent decree in Spain establishes the technical and operational framework for the future mandatory use of e-invoices in B2B transactions.
• The UAE continues to release guidance ahead of its e-invoicing pilot scheduled to begin this summer.

Courts have also been active. The CJEU has clarified several key issues, including the scope of the “standstill clause,” the right to deduct input VAT when invoices are received after the taxable transaction but before the VAT return deadline and the limits of the VAT cost sharing exemption. In France, the Supreme Court has ruled on the joint liability of customs representatives, curtailing administrative practices based on presumed indirect representation. Spain’s high court delivered two notable decisions: one addressing VAT deduction rights for mixed holding companies—long a contentious area—and another on the interaction between Spanish VAT and the Canary Islands’ analogous tax.

On the regulatory front, France and Japan are expanding VAT/JCT to capture more low-value imports. Japan also plans to extend platform taxation to goods beginning in 2028, having already applied it to services. South Africa is proposing to shift VAT liability for electronic services supplied through digital platforms to intermediary operators unless the parties agree otherwise. A new Czech Republic VAT refund mechanism allows non-EU entities to recover VAT on certain transactions without filing a traditional refund claim. Meanwhile in Chile, the tax authorities have issued helpful guidance on the VAT treatment of software licensing and sublicensing. Several jurisdictions, including Denmark, Singapore and Spain, continue to refine “green” initiatives, while others are introducing relief measures to address rising fuel costs.

Explore these topics and more in our April issue and make BDO’s Indirect Tax News your essential source for timely insight and practical analysis!