New Measures Targeting High-Risk VAT Payers and Other VAT Changes

The measures are to be introduced gradually, with proposed effective dates of April 1, 2026, and January 1, 2027.

Proposed Amendments to the VAT Act

Effective from April 1, 2026:

• Extension of the deadline for the tax authority to decide on a voluntary VAT registration application to up to 60 days in justified cases,
• Introduction of the possibility for the tax administrator to impose a record-keeping obligation if risk criteria are met – the VAT payer will be required to submit specified documents to the tax administrator regarding supplies of goods and services, transport documents, delivery notes, copies of invoices, payment documents, and other supporting documents,
• Expansion of the legal grounds for the tax administrator to cancel VAT registration for high-risk entities – for example, repeated issuance of fictitious invoices or claiming VAT deductions on such invoices,
• Establishment of a legal presumption of cessation of economic activity if the VAT payer has not notified the place of business, has only provided a correspondence address, or is repeatedly unreachable.

Effective from January 1, 2027:

• Reintroduction of the VAT guarantee mechanism in the range of EUR 5,000 to EUR 500,000 for potential future VAT arrears, which the tax authority will be entitled to impose if the same risk criteria are met as for the record-keeping obligation.

Other Expected Changes in the Area of VAT

In connection with the mandatory transposition of the ViDA Directive, another separate draft amendment to the VAT Act is expected, which, in stages from January 1, 2027, and subsequently from July 1, 2028, will introduce the following changes:

• Gradual phasing out of the call-off stock regime,
• Taxation of platforms in the short-term accommodation and passenger transport sectors,
• Introduction of a new one-stop-shop scheme for the movement of a business’s own goods to another EU Member State,
• Extension of existing one-stop-shop arrangements,
• Introduction of mandatory reverse-charge mechanism for certain cross-border transactions, and
• Adjustment of rules regarding the person liable to pay VAT on imports in the context of distance sales of goods imported from third countries, where the goods are subject to the special IOSS scheme, and the termination of the special scheme for declaring and paying VAT on imported goods (transposition of the related Council Directive (EU) 2025/1539).

We will keep you informed about further developments related to the implementation of these changes.