High Time to Establish a VAT Group or Modify an Existing One

Taxes

By: Jana Shumakova

Contents

Are you considering establishing a VAT group (or modifying an existing one) so that it is registered effective January 1, 2027? The primary advantage of a VAT group is that its members do not charge VAT on supplies among themselves; a single tax return and control statement are filed for the entire group, resulting in one consolidated tax liability. Consequently, forming a VAT group typically improves the group's cash flow and, in some cases—especially where entities with VAT-exempt activities or non-payers enter the picture, such as various types of holding companies—can also lead to genuine, legal tax savings. In connection with holding companies, we would now like to draw your attention to the latest developments in the case law of the Supreme Administrative Court, which we informed you about in our GT Alert from June 2026, as forming a VAT group can, under certain circumstances, be a highly beneficial element when implementing changes to the holding structure.

The deadline for submitting an application for registration or for any modifications to existing VAT groups is November 2, 2026, provided that these changes are to take effect from January 1, 2027 (otherwise, the formation or changes will only take effect on January 1, 2028). Since last year, the option of a direct transfer of a member from one VAT group to another has also been available.

In the area of VAT groups, we offer a comprehensive range of advisory services, focusing in particular on the following:

  • Analysis of the potential benefits and savings of forming or modifying a VAT group structure;
  • Assessment of compliance with statutory conditions for establishing a VAT group, or assistance with changes in the business structure of companies required to meet these conditions;
  • Preparation and submission of the application for registration or the request for changes within the VAT group;
  • Assistance with setting up internal processes and relationships among VAT group members;
  • Formulation of recommendations and preparation of informational letters regarding business partners.

This text was translated by AI.