For which B2B transactions does the obligation not apply?
The obligation for structured electronic invoicing will almost always apply to transactions between a Belgian VAT-registered supplier and a VAT-registered customer in Belgium, regardless of whether the customer is established in Belgium.
There are a few limited exceptions to this principle:
There is no obligation to send structured electronic invoices for:
- Bankrupt VAT-registered taxpayers,
- Businesses that only perform exempt transactions under Article 44 of the VAT Code,
- VAT-registered taxpayers not established in Belgium without a permanent establishment,
- Flat-rate VAT taxpayers (Article 56 of the VAT Code, phasing out by January 1, 2028 at the latest).
There is no obligation to receive structured electronic invoices for:
- Businesses that only perform exempt transactions under Article 44 of the VAT Code,
- VAT-registered taxpayers not established in Belgium without a fixed establishment.
There is no obligation to send or receive structured electronic invoices if the transaction is exempt under Article 44 of the VAT Code.
Sources
- See also
- Join the Linkedin Group on Global E-Invoicing/E-Reporting/SAF-T Developments, click HERE
Latest Posts in "Belgium"
- Modernisation of the Belgian VAT chain: official timeline confirmed, entry into force on 1 May 2026
- Belgium Clarifies VAT Filing, Objection, and Audit Rules in New Circular Effective January 2026
- Belgium Standardises VAT Filing Rules, Removes Sector Limits, Streamlines Digital Contestation from 2026
- ECJ and EU General Court Issue Key Rulings on ATAD CFC Rules and VAT Treatment
- Belgian Emanation Theory Challenged: EU Court Rules on VAT for Intermunicipal Entities and Associations














