France will abolish the limited fiscal representation for non-EU companies on 31 December 2025. The limited fiscal representation has been popular with British companies, especially since Brexit, for importing goods into France using the “procedure 42” and then transporting them onwards to other EU Member States. Limited fiscal representation meant that companies themselves did not need to register for VAT. EU companies will still be able to use limited fiscal representation. Non-EU companies that use limited fiscal representation in France should therefore adjust their VAT setup there as soon as possible.

 

The Italian tax authorities have clarified in an administrative letter (No. 213/2025) that an importer, who does not own the imported goods, is nevertheless entitled to deduct the import VAT paid on importation, provided that the goods are used for the purpose of carrying out his business activity. The tax authorities emphasized that the importer is obliged to properly record the customs invoice in its ledger of incoming invoices before he can claim his right to deduct input VAT. 

 

The underlying case concerned an Italian contract manufacturer who imported an ingredient for the manufacture of pharmaceuticals without acquiring ownership of the ingredient. The contract manufacturer added other compounds to the ingredient to produce pharmaceuticals as the final product. These were then delivered to the owner of the ingredient, with the goods then being shipped to Germany and Brazil.

 

Poland is preparing for the mandatory 2026 introduction of the e-invoicing system, KSeF. The Polish Ministry of Finance has already presented the expected schedule for the introduction of KSeF. From 1 February 2026, KSeF will become mandatory for companies whose turnover (including tax) exceeded PLN 200 million in 2024. From 1 April 2026, KSeF will become mandatory for all other companies.

 

This obligation applies to taxable persons established in Poland and foreign taxable persons with a permanent establishment in Poland, provided that this permanent establishment is involved in the transactions carried out. This obligation implies that, in general, all invoices must be issued in real time in the KSeF system.

 

Polish KSeF legislation stipulates that if a customer does not have access to the KSeF system, as they may not be subject to the obligation to use the KSeF system for issuing and receiving e-invoices, these invoices can be received by the customer outside the KSeF system. In this case, the supplier is required to send the e-invoice to the customer additionally outside of KSeF, in accordance with the procedure agreed between these two parties.

 

Switzerland had planned to increase its standard VAT rate from the current 8.1% to 8.8% as of 1 January 2026. Following the previous VAT rate increase from 7.7% on 1 January 2024, this would be the second increase in a short period of time. As a result of a referendum on increasing state pensions on 13 September 2025, the government confirmed that it would seek to increase the standard VAT rate by 0.7% in order to finance the pension increase. The planned increase on 1 January 2026 did not receive a majority vote in parliament in October 2025. However, the matter is not yet off the table. The next likely date for an increase in the VAT rate is 1 January 2028.

 

Since 1 July 2025, all taxable persons have been required to submit an electronic statement of the VAT they have charged and the VAT deducted as input VAT. The tax authorities use these statements to prepare a pre-filled tax return. The aim of this measure is to strengthen control options in order to reduce the risk of tax evasion. If irregularities are found, the tax authorities will send warning letters. If the taxpayer concerned continues to work with the listed suppliers after receiving these letters, they will be jointly and severally liable for the VAT that the supplier has not paid. The first checks since July 2025 have already led to the detection of instances of tax evasion.

 

In addition, a government regulation provides for the possibility of avoiding penalties and interest on arrears for outstanding tax liabilities. The measure constitutes a form of tax amnesty. In order to benefit from this regulation, taxable persons who have outstanding tax liabilities as of 30 September 2025 or who have not submitted the necessary tax returns by this date must either settle the outstanding tax arrears or submit the necessary tax returns and settle the resulting tax liabilities during the specified replacement period from 1 January 2026 to 30 June 2026.