As of 6 October 2026, the Directorate General of Taxes (DGT) has clarified that providing meal vouchers, transport cards, or similar flexible remuneration benefits to employees may constitute a taxable supply of goods or services for VAT purposes, obliging the self-employed employer to issue a corresponding invoice. The VAT treatment depends critically on the contractual structure: if the voucher is granted as a salary supplement (in kind) under a flexible pay plan, it may be subject to VAT; if structured as a pure salary sacrifice with specific tax-exempt limits, different rules apply. Misclassification risks VAT penalties and loss of input VAT deduction.
Key Takeaways
- Contractual Form Determines VAT Liability: The distinction between “salary in kind” (taxable supply) and “exempt flexible remuneration” dictates whether an invoice with VAT must be issued to the employee.
- Input VAT Recovery at Stake: Employers treating vouchers as exempt when they are taxable risk having their input VAT deductions on the voucher purchase denied by the Tax Agency.
Disclaimer: This article is compiled and summarized by the AI based on publicly available information and is for general information purposes only. It does not constitute any form of formal tax advice, legal opinion, or basis for performance. Please consult a qualified professional tax advisor or legal counsel for tax advice.
Source: Read Official Announcement