Amendments to the VAT Act and the VAT Ordinance as of 1 January 2026

What entrepreneurs need to know

As of 1 January 2026, amendments to the Value Added Tax Act have entered into force, together with accompanying amendments to the VAT Ordinance that further elaborate the new rules. Although these changes do not represent a radical reform of the VAT system, they are operationally significant, as they directly affect deadlines, reporting, record-keeping, the treatment of advance payments, and the application of Fiscalisation 2.0.

Below is an overview of the key amendments most relevant to entrepreneurs.

New deadlines for submitting VAT returns and related forms

The most important change relates to the extension of deadlines for submitting VAT returns and related forms. Instead of the previous deadline of the 20th day of the month following the tax period, from 2026 onwards returns must be submitted by the last day of the month following the relevant tax period.

This applies to:

• the VAT return (Form PDV),
• the recapitulative statement (ZP),
• the report on the acquisition of goods and services from the EU (PDV-S),
• returns related to procedures 42 and 63.

It is important to note that the VAT payment deadline remains unchanged – the tax liability is still due by the end of the month. For the final tax periods in 2025, the old deadlines continue to apply.

Abolition of certain records and forms

With the aim of reducing administrative burden, the following obligations have been abolished:

• maintaining and submitting the Special Record of Incoming Invoices (U-RA) together with the VAT return,
• submitting the report on domestic supplies subject to the reverse charge mechanism (PPO) for certain activities (e.g. construction services, supplies of waste, reinforcement steel, and real estate transactions subject to the reverse charge).

In addition, amendments to the VAT Ordinance have removed the obligation to maintain the Sales and Purchase Ledger (I-RA and U-RA) as prescribed tax records. However, in practice, many entrepreneurs will continue to keep these records for internal control purposes and due to their integration with accounting systems.

Changes related to invoices and e-invoices

Under the amended regulations applicable from 2026, the obligation to obtain the recipient’s consent for receiving e-invoices is abolished in cases where there is a statutory obligation to issue e-invoices. At the same time, VAT taxpayers who provide VAT-exempt financial services, including currency exchange services, are exempt from the obligation to issue invoices for such services. These changes are aligned with the rules of Fiscalisation 2.0 and the new electronic reporting system.

New VAT return form and food donations

The structure of the VAT return form remains largely unchanged, but a new section has been introduced for reporting food donations. Data on donated food is now reported directly within the VAT return, eliminating the need for a separate food donation report. For entrepreneurs involved in food donations, this means simpler reporting while maintaining applicable tax incentives.

Treatment of advance payments remains unchanged

Despite earlier announcements, the existing rules on advance payments remain in force:

• it is not necessary to issue an invoice for an advance payment if the supply is made and the final invoice is issued within the same tax period;
• if the advance payment and the supply fall into different tax periods, it is mandatory to issue an advance invoice, cancel it, and issue a final invoice, all in accordance with Fiscalisation 2.0.

This decision prevents additional administrative burdens on businesses.

Extension of the deadline for input VAT deduction

In line with the new VAT return submission deadline, the final deadline for claiming input VAT on received invoices has also been extended. Input VAT may be deducted in the period in which the supply was made, provided that the invoice is received no later than the date of submission of the VAT return for that period. If the invoice is received after that deadline, the right to deduct input VAT is exercised in the period in which the invoice is actually received.

New PDV-P form for VAT refunds to travellers

A new PDV-P form is introduced for VAT refunds to private individuals from third countries within the framework of passenger traffic. While the basic refund rules remain unchanged, the procedure and content of the form are further specified, including the possibility of electronic completion.

Conclusion: operational changes requiring adjustment

The VAT amendments effective in 2026 do not change the fundamental principles of VAT taxation, but they significantly affect how these rules are applied in day-to-day business operations. Particular emphasis is placed on process digitalisation, alignment with the fiscalisation system, and more precise deadlines and records. For many VAT taxpayers, this means the need to adjust internal procedures and IT systems.

Timely analysis of how these changes impact specific business models, as well as the alignment of operational and accounting processes, is essential to reduce tax and regulatory risks. In cases of uncertainty regarding the interpretation or practical application of the regulations, seeking professional advice is recommended.

brandom provides advisory support in analysing, interpreting, and implementing tax changes, with the aim of ensuring compliance and legal certainty in business operations. Contact us!