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Regulatory Intelligence

Cross-border tax & product compliance, tracked weekly.

Court of Justice of the EU judgments, PPWR and EPR developments, GPSR enforcement and Italian fiscal updates. Curated for SMEs and enterprises selling into Italy, the EU and the UK.

Tracked jurisdictions 35+
ECJ cases monitored 2026 YTD
Briefing cadence Weekly
ECJ VAT Case Law

Recent CJEU judgments that change how you operate.

Three judgments from the Court of Justice of the European Union and General Court that materially affect non-resident sellers, fiscal representation arrangements, and VAT input recovery. Reviewed by our advisory team and contextualised for SMEs and enterprises.

C-603/24 21 May 2026

Stellantis Portugal Lda

The Court ruled on the conditions under which a Portuguese subsidiary could recover input VAT on intra-group services where the parent company's recharge model affected the place-of-supply analysis. The judgment clarifies application of Article 168 of the VAT Directive in transfer-pricing contexts.

Holding

Input VAT recovery cannot be denied solely because intra-group recharges adjust the taxable amount, where the underlying supply qualifies as economic activity for VAT purposes.

What this means: Multinationals with intra-group recharges flowing through Italian subsidiaries should review whether historical input VAT denials are now actionable for refund claims.

T-231/26 14 April 2026

Genova Margin Scheme Dispute

General Court decision on the application of Italy's margin scheme (regime del margine) to used-goods imports where the original supplier's status as a taxable dealer was contested. The case turned on documentary evidence requirements under Article 314 of the VAT Directive.

Holding

Margin scheme application requires positive evidence that the original supplier qualifies under Article 314. Absence of evidence shifts the burden to the importer to apply standard VAT treatment.

What this means: Sellers of used goods importing into Italy must maintain robust supplier qualification evidence at the point of acquisition or face retrospective full-rate VAT assessment.

C-307/23 12 March 2026

G GmbH (Customs Valuation)

The Court addressed whether royalty payments made by an importer to a third-party rights holder must be included in the customs value of imported goods under Article 71 of the Union Customs Code. The judgment refines the "condition of sale" test for transfer pricing adjustments.

Holding

Royalties are addable to customs value only where their payment is a condition of sale of the imported goods. Indirect contractual links between rights holder and seller are insufficient.

What this means: Brand-led importers with separate royalty arrangements should reassess customs declarations made on the assumption that all royalties were addable. Refund claims may be available.

Case summaries are prepared by CiDATax for orientation only. They do not constitute legal advice and should not be relied upon for transactional decisions. Always consult counsel on the application of these judgments to your specific circumstances. Primary case texts are available via curia.europa.eu.

Regulatory briefings.

Tracked across the EU 27, the UK, the US and our priority international markets. Updated weekly by the CiDATax advisory team.

EPR · PPWR 22 May 2026

PPWR 12 August 2026 deadline: PRO registrations now bottlenecked across DE, FR, IT

National Producer Responsibility Organisations report registration backlogs of 4 to 8 weeks. Non-EU sellers without an Authorised Representative in place by mid-June risk missing the enforcement date entirely.

GPSR 18 May 2026

EU Safety Gate Q1 2026: 41 percent rise in product recalls naming non-EU sellers

Safety Gate notifications now systematically identify the EU Responsible Person on listing pages. Sellers without a named Responsible Person are being delisted within 72 hours by major marketplaces.

Italy · VAT 15 May 2026

Agenzia delle Entrate: pre-filled VAT returns expansion to include OSS data from Q3 2026

Italy's tax authority confirms that VAT pre-compiled returns (LIPE and dichiarazione annuale) will incorporate data received via the OSS One-Stop-Shop from third quarter 2026, with mismatches triggering automated audits.

VAT · OSS 9 May 2026

ViDA package status: e-invoicing mandate timeline extended to 2030 for intra-EU B2B

The VAT in the Digital Age (ViDA) package's structured e-invoicing requirements for cross-border B2B transactions have been pushed back, but real-time digital reporting obligations remain on track for 2028.

Customs · UCC 6 May 2026

EU Customs Reform: centralised clearance and the new EU Customs Authority proposal

European Commission reform package proposes consolidated customs clearance, an EU Customs Data Hub, and a new EU Customs Authority. Implementation phased between 2028 and 2032, but importers should begin scenario planning.

UK VAT 2 May 2026

HMRC Making Tax Digital: phase 3 brings sub-thresholds and group VAT online

UK Making Tax Digital phase 3 brings VAT-registered businesses with turnover under £85,000 into mandatory digital filing from October 2026. Group VAT registrations also move to MTD-compatible software requirements.

Italy · CONAI 28 April 2026

CONAI eco-contribution 2026: paper, plastic and aluminium rates revised upward

Italy's national packaging consortium has confirmed revised eco-contribution rates for 2026. Plastic packaging contributions increased to align with PPWR modulation principles. Annual declaration filings due 20 June 2026.

IOSS 25 April 2026

IOSS misuse crackdown: Member States flag 1.2 million suspect IOSS numbers

Coordinated EU customs action has identified IOSS numbers being shared, recycled or falsely declared on imports under €150. Penalty assessments now flowing to platforms and consolidators. Verified IOSS intermediaries gain commercial advantage.

Customs · Origin 20 April 2026

CBAM Q1 2026 reports: 89 percent rejection rate signals embedded-emissions enforcement

The Carbon Border Adjustment Mechanism transitional period continues. First-quarter reports show widespread rejection of submissions lacking verified embedded-emissions data for cement, steel, aluminium, fertilisers and electricity.

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The latest articles on cross-border compliance, VAT strategy, and regulatory developments — published automatically and kept current.

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