News

Sep 19, 2025

Update of the EU List of Dual Use Items

Annex I of Regulation (EU) 2021/821 ("Dual-Use Regulation"), which lists goods, including software and technologies, that are to be classified as "dual-use" - meaning they are fit for civil as well as military use - and which are therefore always subject to an authorization requirement when exported from the EU, is usually updated once a year. On September 5, 2025, the European Commission published the draft of a Delegated Regulation amending Annex I (C(2025) 5947 final). The announced update brings numerous new technical entries, particularly in the areas of semiconductor technology, cryotechnology, and quantum computing. Companies that export goods to third countries should familiarize themselves with the changes shortly. The legal act is expected to enter into force at the end of 2025.

Sep 9, 2025

VAT Exemption on Exports: Actual Circumstances are Decisive

In its judgment of 1 August 2025 in Case C602/24, the Court of Justice of the European Union (CJEU) addressed the conditions for the exemption from value added tax (VAT) in the context of the export of goods under Directive 2006/112/EC on the common system of value added tax. The Court clarified that supplies may qualify for VAT exemption even if they were initially declared by the supplier as intra-Community supplies but were subsequently exported to third countries by the purchaser without the supplier’s knowledge. The Court thereby reaffirmed that it is the actual circumstances of the transaction that are decisive for the VAT exemption and that the intentions or assumptions of the taxable person are irrelevant. National formal requirements may not contradict this principle. However, this does not apply where the taxable person has acted in bad faith. Continuing its established case-law, the Court emphasized the principle of fiscal neutrality, the importance of good faith, and the irrelevance of formal breaches where the substantive conditions for VAT exemption are met.

Sep 1, 2025

Iran embargo: Invocation of the snapback mechanism

On 28 August 2025, Germany, France and the United Kingdom triggered the snapback mechanism provided for in Security Council Resolution 2231 (2015). This could lead to the reinstatement of economic sanctions against Iran imposed by the UN Security Council. The sanctions had been suspended in 2015 in return for Iran's commitment to dismantle its nuclear programme under the Joint Comprehensive Plan of Action (JCPoA). Due to Iran's ongoing violations of its JCPoA commitments and the failure of negotiations on a possible successor agreement, the sanctions could now be reinstated unless an agreement is reached within 30 days.

Aug 22, 2025

Consultations for Environmental Omnibus

On 22 July 2025, the European Commission (EC) launched a Call for Evidence in preparation of its forthcoming Environmental Omnibus Proposal. The proposal aims to simplify and streamline administrative requirements related to the environment especially in the areas of waste, products, and industrial emissions, and reduce the administrative burden placed on companies, without affecting the policy objectives pursued by the legislation. We give an overview of this Omnibus and how stakeholkders can participate.

Aug 6, 2025

EU Commission presents comprehensive proposal to revise the Tobacco Tax Directive

On July 16, 2025, the European Commission presented a comprehensive proposal for a revision of Directive 2011/64/EU (Tobacco Tax Directive). The revision of the Tobacco Tax Directive aims to fundamentally modernize the taxation of tobacco and related products.

Aug 4, 2025

18th sanctions package: EU replaces SWIFT exclusion with comprehensive transaction ban on listed banks

With its 18th sanctions package, the European Union is tightening its financial measures against Russia and Belarus. The former SWIFT exclusion is being replaced by a comprehensive transaction ban that prohibits not only technical communication but also any economic interaction with listed financial institutions.

News

Update of the EU List of Dual Use Items

VAT Exemption on Exports: Actual Circumstances are Decisive

Iran embargo: Invocation of the snapback mechanism

Consultations for Environmental Omnibus

EU Commission presents comprehensive proposal to revise the Tobacco Tax Directive

18th sanctions package: EU replaces SWIFT exclusion with comprehensive transaction ban on listed banks

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