Belgium – Public Bodies – General Court Rules Intermunicipal Association is Liable for VAT
Summary
In Case T-575/24 (Digipolis), the General Court ruled that a public law body created for intermunicipal cooperation is liable for VAT on services provided to its members for remuneration. The Court rejected the “emanation” theory, a Belgian administrative practice that treated the association as an extension of its public authority members and thus outside the scope of VAT. It was determined that Digipolis operated independently and engaged in economic activity, and treating its services as non-taxable would lead to significant distortions of competition. This ruling clarifies that public law bodies are subject to VAT when they perform economic activities under similar conditions as private operators.
Belgium – Travel Services – EU Court Upholds Historical VAT on Non-EU Travel
Summary
The EU General Court, in case T-221/25, upheld Belgium’s historical application of VAT on travel agency services for travel outside the EU. The ruling is based on the “standstill provision” of the VAT Directive, which allowed Member States to continue taxing certain transactions that were already subject to VAT upon their accession. The Court clarified that an explicit derogating provision in national law was not required for the standstill to apply; implicit confirmation is sufficient. This decision impacts the travel sector by settling a long-running dispute concerning the period before May 1, 2014, after which Belgium explicitly exempted these services.
Belgium – Procedural Rules – New Digital VAT Provision Account System from May 2026
Summary
As part of its VAT chain modernization, Belgium will launch a new digital VAT provision account system via the MyMinfin portal, effective May 1, 2026. This new system replaces the current VAT current account and requires businesses to use a new, specific bank account for VAT payments. The reform aims to streamline VAT management by centralizing payments and refunds. Key changes include the abolition of the “summer scheme” for filing extensions and new rules limiting refunds on periodic returns to the amount in box 72, with remaining credits claimed separately. This impacts all VAT-liable businesses, which must adapt their payment and refund processes.
Source Belgium Launches New VAT Provision Account and Payment Rules from May 2026 – VATupdate
Belgium – VAT Rates – Rate Increases for Accommodation and Pesticides from March 2026
Summary
Belgium has increased the VAT rate on certain goods and services effective March 1, 2026. The rate for hotel stays, furnished accommodation, and campsites has doubled from 6% to 12%. A transitional measure allows the 6% rate for bookings made by February 28, 2026, provided the VAT becomes chargeable by June 30, 2026. Additionally, the VAT rate on phytopharmaceutical products, such as pesticides, will increase to the standard rate of 21%. These changes, part of the federal budget agreement, will directly impact businesses in the hospitality, tourism, and agricultural sectors by increasing their costs and affecting consumer pricing.
Source Belgium Raises VAT on Pesticides to 21% and Accommodation to 12% from March 2026 – VATupdate
Belgium – E-invoicing – Sanctions for Non-Compliance Begin in April 2026
Summary
The three-month grace period for non-compliance with Belgium’s mandatory B2B e-invoicing requirements ended on April 1, 2026. From this date, full enforcement is in effect, and businesses that fail to issue or receive structured electronic invoices via the Peppol network for domestic B2B transactions will face sanctions. Penalties for non-compliance can be significant, ranging up to €5,000. This marks a critical deadline in the country’s transition to a fully digital tax environment, requiring all VAT-registered businesses to ensure their systems are compliant to avoid financial penalties and operational disruptions. An extended tolerance until June 30, 2026, applies only for self-billing invoices.
Source Belgium Ends Grace Period for B2B E-Invoicing: Sanctions Begin April 2026 – VATupdate
Belgium – VAT Registration – Exemption Threshold for Small Businesses Raised
Summary
The Belgian government has approved an increase in the VAT exemption threshold for small businesses, raising the annual turnover limit from €25,000 to €30,000. This measure is part of a broader administrative simplification package and aims to reduce the compliance burden for micro-enterprises and the self-employed. Businesses operating under this optional scheme can supply goods and services without charging VAT but lose the right to deduct input VAT. The change requires parliamentary approval to be enacted. Once effective, more businesses will be eligible for the simplified regime, though they can still opt for normal VAT registration.
Belgium – Fiscalization – Deadlines Confirmed for Hospitality Cash Register Upgrades
Summary
The Belgian tax authority has confirmed the deadlines for the mandatory implementation of the new certified cash register system, GKS 2.0, for the hospitality (HoReCa) sector. Despite an extended tolerance period until June 30, 2026, due to limited availability of certified hardware, the official implementation date remains January 1, 2026. During the tolerance period, businesses can adopt GKS 2.0, register online while awaiting hardware, or temporarily use the older GKS 1.0 system to remain compliant. This impacts all hospitality and catering businesses, which must upgrade their systems to ensure real-time, secure transaction recording for VAT purposes.
Belgium – Compliance – Annual VAT Client Listing Submission Deadline
Summary
The deadline for all Belgian VAT-registered businesses to submit their annual client listing for the 2025 calendar year is March 31, 2026. [33] [34] [35] [36] [37] This mandatory report must detail all sales exceeding €250 (excluding VAT) to each Belgian VAT-registered customer. [34] [35] [36] The submission must be made electronically through the Intervat portal. [34] [37] A significant change from 2026 is that small businesses operating under the VAT exemption scheme must also file this listing, even if they have no transactions to report (a “nil” listing). [33] [34] [36] Failure to submit the listing on time can result in administrative penalties. [35]
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