Did you know that a tax guarantee may be reintroduced for VAT registration?

Changes effective from 1 April 2026

For voluntary VAT registration, the amendment proposes:

• Extending the decision period from 21 to 60 days if the tax authority has doubts.
• Giving the tax authority the option to impose a record‑keeping obligation if the applicant meets certain risk criteria.

Changes effective from 1 January 2027

A tax guarantee would be reintroduced but in a more targeted and moderate form than before:

• It would apply only to high‑risk taxpayers (i.e. those with tax arrears exceeding EUR 5,000 or with a risky tax history).
• It would not be imposed automatically on all applicants - only where the tax authority has doubts about their ability to comply with tax obligations.
• The guarantee amount would be set individually, ranging from EUR 5,000 to EUR 500,000.
• The guarantee would primarily serve to cover potential tax arrears during the first 12 months. If unused, it would be refunded to the taxpayer.

✏️ Important notice

These are draft legislative changes, not yet adopted. Their objective is to prevent VAT registration of entities that present an increased risk of future tax arrears based on their current or past compliance record.

The changes are therefore targeted and will not affect the majority of standard applicants.

💡 Have questions?

Our tax team at Forvis Mazars will be happy to advise you on how to prepare for the proposed changes. Contact us via details below.

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The tax environment is a subject to frequent changes. We strive to reflect the current state as accurately as possible, but all information on our website is valid as of the date of publication. If you have any questions or uncertainties, please don’t hesitate to reach out to us. We will assess the current impact of any tax-specific issue on your situation or company.