Matters considered by the Project Office for the Implementation of the Tax Code

The Project Office considered, among other things, the following matters:

1. The deadline for issuing electronic invoices (e‑invoices) for Reverse Charge VAT on services acquired from non‑residents could be revised retroactively¹

Currently, the Tax Code requires that an e‑invoice be issued no later than 5 calendar days after the Reverse Charge VAT payment (para. 9 of Art. 493 of the Tax Code).

It is proposed to simplify the mechanism by introducing a single deadline of 15 calendar days from the date the taxable turnover for acquiring services from a non‑resident occurs. The RC VAT offset will be taken based on the date the RC VAT is paid. These amendments are planned to be introduced retrospectively from 1 January 2026.

Until the amendments enter into force, VAT payers should comply with the current 5‑day rule.

The VAT return for Q1 2026 should be submitted between 15 April and 15 May 2026 (para. 1 of Art. 505 of the Tax Code).

2. Proposal to abolish the requirement to issue electronic invoices (e-invoice) for interest income on loans²

Turnover related to interest on credits, loans, and microloans is exempt from VAT (Art. 474 of the Tax Code). However, due to inaccuracies in the wording, such turnover is not included in the list of transactions for which the issuance of an e-invoice is not required.

Accordingly, it is proposed to abolish the requirement to issue e-invoice for these transactions and to apply this rule retrospectively from 1 January 2026.

Until the amendments enter into force, the current requirements of the Tax Code should apply.

3. Payment of MET on common minerals at the place of extraction³

In accordance with the Budget Code mineral extraction tax (MET) on common minerals is paid to the budgets at the location of the extraction site, whereas the Tax Code provides for the payment of MET at the place of registration of the subsurface user.

It is proposed to introduce amendments to the Tax Code and reporting forms in order to align the provisions of tax legislation with the budget legislation.