Tax News Daily
The latest tax news from around the world, summarised and tagged for tax professionals. Updated twice daily.
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IRAS Updates ACAP Post-Review and Renewal Requirements
The Inland Revenue Authority of Singapore (IRAS) has updated the requirements for the Assisted Compliance Assurance Programme (ACAP), specifically around post-review obligations and renewal procedures. ACAP is a GST-focused programme that recognises businesses with robust tax governance and internal controls. The revised requirements are likely to affect how companies maintain their ACAP status and prepare for renewal assessments. Businesses holding or seeking ACAP certification will need to review their compliance frameworks against the updated criteria. The changes signal IRAS's continued emphasis on proactive tax governance and the importance of sustained internal compliance standards beyond initial accreditation.
SARS introduces early-warning system to reduce tax filing errors and audits
The South African Revenue Service (SARS) has introduced an early-warning system designed to proactively alert taxpayers to potential errors in their tax filings before submissions are finalised. The system aims to reduce the volume of incorrect returns, minimise costly audits, and improve overall compliance rates. By flagging discrepancies or anomalies in real time, SARS intends to ease the administrative burden on both taxpayers and the authority. This initiative reflects SARS's ongoing investment in technology-driven compliance tools and represents a significant step toward a more collaborative, pre-emptive approach to tax administration in South Africa.
ECJ/General Court VAT Cases – Pending cases
This resource compiles and tracks pending VAT cases before the European Court of Justice (ECJ) and the General Court, providing an overview of ongoing litigation that could shape EU VAT law. The list serves as a reference tool for tax practitioners monitoring developments in EU VAT jurisprudence. These pending cases span various VAT issues across multiple member states and represent potential landmark rulings that could affect how VAT Directive provisions are interpreted and applied across the European Union.
Roadtrip through ECJ Cases – Focus on ”Exemption – Financial transactions – Credits and transfer of Credits” (Art. 135(1)(b))
This article explores ECJ case law focusing on VAT exemptions for financial transactions related to credits and the transfer of credits under Article 135(1)(b) of the EU VAT Directive. It reviews how the ECJ has interpreted and applied this exemption across multiple decisions, mapping the evolution of the legal principles involved. The analysis is valuable for financial institutions and tax practitioners seeking to understand the boundaries of VAT-exempt lending and credit-related services under EU law.
Roadtrip through ECJ Cases – Focus on ”Exemption – Financial transactions – deposit and current accounts, payments, transfers, debts, cheques and other negotiable instruments” (Art. 135(1)(d))
This article examines ECJ case law on the VAT exemption for financial transactions under Article 135(1)(d) of the EU VAT Directive, covering deposit and current accounts, payments, transfers, debts, cheques, and other negotiable instruments. It surveys how the ECJ has interpreted this exemption across various rulings, clarifying the scope of exempt payment and transfer services. The analysis helps financial services firms and tax advisors determine which transaction types qualify for VAT exemption under EU jurisprudence.
ECJ & General Court VAT Cases decided in 2026
This resource compiles all ECJ and General Court VAT decisions issued during 2026, serving as a comprehensive reference guide for EU VAT case law in the current year. It tracks rulings across a range of VAT issues and member states, reflecting the ongoing development of EU VAT jurisprudence. Tax practitioners and advisors can use this compilation to monitor significant judicial interpretations of the EU VAT Directive and understand how courts are resolving disputes brought by businesses and tax authorities.
Court of Appeal Rules Bolt Ride-Hailing Services Outside TOMS
The Court of Appeal has ruled that Bolt's ride-hailing services fall outside the Tour Operators' Margin Scheme (TOMS), a VAT margin scheme originally designed for travel businesses. The judgment determines that Bolt does not meet the criteria for TOMS application, meaning the platform cannot calculate VAT solely on its margin. The ruling has significant implications for gig-economy ride-hailing platforms regarding their VAT accounting obligations and potentially increases their VAT liability. It also contributes to ongoing debate about how VAT rules apply to digital platform-based transportation services.
No VAT Deduction on Car Purchase: Entrepreneurship Not Proven
A court denied a VAT deduction claimed on a car purchase because the taxpayer failed to sufficiently demonstrate entrepreneurship status. The ruling underscores that VAT input tax deductions are only available to those acting in the capacity of a taxable person engaged in economic activity. Where a claimant cannot prove they were conducting a genuine business enterprise at the time of the purchase, the right to deduct input VAT is disallowed. This case highlights the evidentiary burden taxpayers must meet to establish business use and entrepreneurial standing for VAT recovery purposes.
No Interest Accrues When VAT Refunds Are Suspended Pending Guarantee Documents
A ruling clarifies that no interest accrues on VAT refunds that are suspended while taxpayers are required to provide guarantee documents. The decision addresses the timeline for interest entitlement, finding that the suspension period pending submission of guarantees does not trigger interest obligations on the tax authority. This has practical implications for businesses awaiting VAT refunds who must first satisfy documentary or security requirements before refunds are released, effectively meaning the clock for interest does not run during that administrative holding period.
Court of Appeal Rules Bolt PHV Services Not Eligible for TOMS
The UK Court of Appeal has ruled that Bolt's private hire vehicle (PHV) services do not qualify for the Tour Operators' Margin Scheme (TOMS). TOMS is a special VAT accounting scheme designed for businesses buying and reselling travel services. The ruling clarifies the boundaries of TOMS eligibility for ride-hailing and PHV operators, with significant implications for how platforms like Bolt account for VAT on their transportation services in the UK. The decision adds to ongoing legal scrutiny of gig economy platforms and their VAT treatment.
VAT Establishment Pitfalls: Lessons from HMRC Practice and Case Law
This analysis examines common pitfalls surrounding VAT establishment rules in the UK, drawing on HMRC practice and relevant case law. The piece explores how the concepts of 'place of establishment' and 'fixed establishment' are interpreted for VAT purposes, with particular focus on scenarios where businesses inadvertently create taxable presences or mischaracterise their VAT position. Key lessons from tribunal and court decisions highlight risks for international businesses operating in the UK, including VAT grouping complications and recovery issues. The article provides practical guidance for businesses to audit their establishment positions and avoid costly compliance errors.
Barclays Fails Appeal on UK VAT Grouping and Fixed Establishment
Barclays has lost its appeal concerning UK VAT grouping rules and the concept of fixed establishment. The case examined whether certain overseas entities or branches could be included in Barclays' UK VAT group and whether the relevant establishments met the legal threshold of 'fixed establishment' for VAT purposes. HMRC's position was upheld, with the tribunal or court finding that the contested entities did not satisfy the necessary criteria. The ruling has broader implications for financial services groups structuring their UK VAT groups and claiming input tax recovery through group membership, reinforcing HMRC's strict approach to fixed establishment determinations.
Lawmakers reject FBR proposal to access bank account data
Pakistani lawmakers have rejected a proposal by the Federal Board of Revenue (FBR) to gain access to citizens' bank account data. The FBR had sought this access as part of efforts to broaden the tax base and improve compliance monitoring, but parliamentarians raised concerns over privacy rights and potential misuse of financial information. The rejection represents a significant setback for the tax authority's data-driven enforcement strategy. This dispute highlights ongoing tensions between revenue collection ambitions and civil liberties protections in Pakistan's tax administration reform agenda.
Substantial additional VAT assessments for tablet and phone traders not too high
A court upheld substantial additional VAT assessments imposed on traders dealing in tablets and phones, ruling the amounts were not disproportionately high. The case involved traders found to have under-reported VAT liabilities, likely in connection with supply chain fraud or under-declaration of sales. The ruling confirms tax authorities' right to levy significant additional assessments in sectors prone to VAT carousel or missing trader fraud, reinforcing that penalties and back-taxes in the electronics trading sector will be scrutinised but not automatically reduced on proportionality grounds.
Comments on T-184/25 (A) – Management of Securitised Mortgages is Taxable
This article comments on case T-184/25 (A), examining whether the management of securitised mortgages constitutes a taxable supply for VAT purposes. The court found that such management services do not qualify for the VAT exemption typically applied to financial services, rendering them taxable. The ruling has significant implications for securitisation vehicles and servicers, as it narrows the scope of VAT exemptions in mortgage management and may increase VAT costs for financial institutions involved in securitisation structures across EU jurisdictions.
False Invoices, VAT Credit Denial and Income Tax Consequence
This article explores the dual tax consequences of false invoicing: denial of input VAT credits and additional income tax implications. When businesses use fictitious or fraudulent invoices, tax authorities not only disallow VAT deductions but also treat the inflated or fabricated expenses as non-deductible for corporate income tax purposes. The piece highlights how false invoicing schemes trigger compounding tax liabilities across both VAT and income tax regimes, exposing businesses to significant financial penalties, interest charges, and potential criminal liability for tax fraud.
Meta Says IRS Seeks 'Do-Over' Of Facebook Case
Meta is challenging the IRS in a high-stakes transfer pricing dispute over the Facebook case, arguing that the IRS is improperly seeking a 'do-over' of the litigation. The case centers on how Meta valued intellectual property transferred to an Irish subsidiary in 2010, with the IRS alleging billions in unpaid taxes. Meta contends the agency is attempting to relitigate settled factual findings from prior proceedings. The outcome could have significant implications for how multinational corporations structure intercompany IP transfers and the IRS's authority to revisit previously adjudicated transfer pricing determinations.
Confusing CP53E Notices from IRS Results in AICPA Requesting Adjustments and Offering Recommendations on Their Use
The AICPA has raised concerns about confusing CP53E notices issued by the IRS, which relate to electronic payment processing issues. The professional body is requesting the IRS make adjustments to how these notices are drafted and used, citing that the current format is misleading taxpayers and practitioners. The AICPA has submitted formal recommendations to improve clarity and reduce unnecessary compliance burden. CP53E notices are sent when the IRS cannot process a direct debit payment, and unclear communications have led to taxpayer confusion about their obligations and potential penalties.
Court of Appeal overturns TOMS decisions on ride-hailing – Bolt Services
The UK Court of Appeal has overturned earlier tribunal decisions regarding the application of the Tour Operators' Margin Scheme (TOMS) to ride-hailing services provided by Bolt. The case examines whether Bolt, as a platform facilitating passenger transport, qualifies for TOMS VAT treatment—a margin scheme originally designed for travel businesses buying and reselling travel services as principal. The Court of Appeal's ruling has significant implications for the gig economy and platform businesses, clarifying how VAT applies to digital intermediaries in the transport sector and potentially affecting the VAT compliance obligations of similar ride-hailing operators.
Comments on T-184/25 (A) – Management of Securitised Mortgages is Taxable
This article comments on case T-184/25 (A), addressing whether the management of securitised mortgages constitutes a taxable supply for VAT purposes. The decision challenges the assumption that such management services fall within the VAT exemption for financial services. The ruling suggests that active management of securitised mortgage portfolios goes beyond passive administration, making it taxable rather than exempt. This has material implications for financial institutions and special purpose vehicles involved in securitisation structures, affecting their VAT recovery positions, pricing of management fees, and overall structuring of mortgage-backed securitisation transactions.
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