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"
- Comments on GC T‑575/24 – AG – Contrary to EU law if services provided to members are regarded as internal acts
- E-Invoicing in Belgium – Factsheet
- Comments on ECJ case C-234/24 (Brose Prievidza):No VAT Exemption for Tooling Without Physical Movement
- Who Must Comply with Belgium’s 2026 eInvoicing Mandate? Scope, Impact, and Preparation Steps
- Belgium’s Mandatory eReporting: The Next Step in Digital VAT Compliance After eInvoicing
