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Comprehensive VAT Guide – Belgium (2026)

Comprehensive VAT Guide – Belgium (2026)

Belgium (Belgique/België) – as a founding EU member – operates a VAT system aligned with EU Directives. This guide details Belgium’s VAT regime in clear sections:

Standard VAT Rate: 21%

  • Applicable to most goods and services

Reduced VAT Rates: 12% & 6%

  • 12% (e.g. restaurants without alcohol); 6% (basic goods, utilities, etc.)

Small Business Threshold: €25,000

  • Turnover exemption for resident businesses (VAT registration not required below this annual amount)

Filing Frequency: Monthly / Quarterly

  • Monthly returns due 20th; quarterly (if eligible) due 25th of the next month

 E-invoicing Mandate 2026

Belgium will require domestic B2B e-invoicing as of 1 Jan 2026. Invoices between Belgian VAT-registered businesses must be issued electronically (via Peppol network), though there is no real-time clearance by the tax authority. Businesses should prepare now for compliance with this digital invoicing shift.

🌱 Green VAT Reforms

Effective 1 July 2025, VAT rates were adjusted to promote climate goals. Installation of fossil-fuel heating systems and coal sales moved from reduced rates to the 21% standard rate, while heat pumps enjoy a temporary cut to 6% VAT (2026–2030). Additionally, a temporary 6% VAT on new homes after demolition was made permanent under strict conditions.


1. Country Overview

Economic Context: Belgium is a highly developed EU economy that adopted VAT in 1971, replacing a former turnover tax. As a member of the EU, Belgium’s VAT system is harmonized with the EU VAT Directive (2006/112/EC). VAT (locally called “BTW” in Dutch and “TVA” in French) is administered at the federal level by the Ministry of Finance (FPS Finance). The currency is the Euro (€), and all VAT accounting is in EUR. [EY worldwi…tax guide | PDF] [fonoa.com], [vatcalc.com]

Tax Authority: The General Administration of Taxes (Algemene Administratie van de Fiscaliteit / Administration Générale de la Fiscalité) oversees VAT policy and audits. Local VAT offices handle registrations, filings, and refunds. Electronic filing is mandatory for returns and statements (via the InterVAT platform). Belgium’s government has a strong focus on digitization and anti-fraud measures in VAT (e.g. certified cash registers, upcoming e-invoicing, data matching). [fonoa.com] [vatcalc.com] [fintua.com]

EU Membership Influence: Being in the EU means intra-EU trade is VAT-exempt for exports and taxed on arrival (intra-Community acquisitions) and that EU-wide initiatives (like the One-Stop Shop for e-commerce, or upcoming “VAT in the Digital Age” reforms) are implemented in Belgium.

2. Local VAT Term

In Belgium, VAT is known by local names reflecting the country’s official languages: “Taxe sur la Valeur Ajoutée (TVA)” in French and “Belasting over de Toegevoegde Waarde (BTW)” in Dutch. These terms appear on invoices and official forms. Many official documents are bilingual. English references simply use “VAT.” [vatcalc.com]

Belgian VAT legislation is contained in the Belgian VAT Code (Code TVA / BTW-Wetboek) and royal decrees, with terminology closely mirroring EU definitions. For example, a VAT registration number is often called “Numéro de TVA” or “BTW-nummer,” and invoices must mention “TVA” or “BTW” accordingly.

3. VAT Rates

Standard Rate – 21%: Belgium’s standard VAT rate is 21%, applying to most goods and services. Unless a specific provision qualifies a supply for a reduced rate or exemption, 21% VAT is charged on the taxable amount. [fonoa.com]

Reduced Rates – 12% and 6%: Belgium has two reduced VAT rates: 12% and 6%. The 12% rate is relatively narrow, covering items like restaurant and catering services (food served on premises, excluding alcoholic beverages) and certain social housing construction/services. The 6% rate is broader and applies to many “basic” or socially important goods and services, for example: [fonoa.com] [fonoa.com], [taxsummaries.pwc.com]

  • Foodstuffs and non-alcoholic beverages (basic groceries) and water supply to households.
  • Pharmaceuticals and medical products.
  • Books, newspapers, and periodicals (including e-books and digital newspapers). [taxsummaries.pwc.com], [vatcalc.com]
  • Passenger transport (e.g. bus, train, flights within EU) and hotel accommodation. [fonoa.com], [taxsummaries.pwc.com]
  • Cultural, sporting, and entertainment admissions (museums, concerts, cinema tickets, etc., often at 6%).
  • Renovation and repair of private dwellings older than 10 years (e.g. building renovation services, installations in homes – this includes heating installations for older homes). [facq.be], [taxsummaries.pwc.com]
  • Certain energy products and utilities: e.g. household electricity and residential heating gas were moved to 6% in 2022–2023 to combat energy costs (this became permanent for households in 2023). [taxsummaries.pwc.com]
  • Other specific items: bicycles (and repair services), some agricultural supplies, funeral services, etc.

Zero Rate – 0%: Belgium applies a 0% zero-rate to very limited supplies beyond the standard EU zero-rated categories (exports and intra-EU supplies):

  • Exports of goods to outside the EU are zero-rated (VAT-exempt with credit). [fonoa.com]
  • Intra-Community supplies of goods to VAT-registered customers in other EU countries are zero-rated (with required proof of transport and the customer’s VAT ID). [fonoa.com]
  • Certain international services can be zero-rated: e.g. cross-border freight transport services in some cases, supplies to diplomats or NATO, and gold supplies to central banks. [taxsummaries.pwc.com]
  • As of 2024, Belgium also zero-rated COVID-19 vaccines and in vitro diagnostic medical devices, following EU rules (this was an emergency measure). Generally, however, Belgium did not adopt broad new 0% rates after the 2022 EU VAT Directive changes (which allowed optional zero rates for some items).

Exempt Supplies: Additionally, many activities are exempt (no VAT charged, no input credit) under Article 44 of the VAT Code, aligning with EU law. Major VAT-exempt sectors in Belgium include: [vatcalc.com], [taxsummaries.pwc.com]

  • Financial and insurance services (banking, lending, finance transactions, insurance premiums) – no VAT on these, and generally no input VAT recovery for providers.
  • Health and medical care – services by doctors, hospitals, dental care, etc., are exempt (healthcare is outside VAT scope in the public interest). [taxsummaries.pwc.com]
  • Education – school and university tuition, and related educational services are exempt. [taxsummaries.pwc.com]
  • Social services – e.g. certain non-profit social care, charity work.
  • Real estate and leasing: The sale of real estate (land and used buildings) and renting/letting of immovable property are generally exempt (with an option to tax some B2B rents – see Section 25). [EY worldwi…tax guide | PDF], [taxsummaries.pwc.com]
  • Cultural and sports – services by non-profit organizations in sport, and certain cultural events or royalties can be exempt.
  • Postal services (public postal service) and public broadcasting are exempt.
  • Passenger transport outside EU (e.g. international flights) is treated as exempt with credit (effectively zero-rated) in many cases. [taxsummaries.pwc.com]

Recent/Upcoming Rate Changes: Belgium has enacted notable VAT rate changes in the 2023–2025 period as part of fiscal and climate policy:

  • Housing: A temporary 6% VAT incentive on demolition and reconstruction of dwellings (introduced in 2021) was made permanent from 1 July 2025. Under this measure, the sale of a new home following demolition of an old building qualifies for 6% (instead of 21%) if strict conditions are met – the dwelling must be used as the buyer’s sole personal residence (or rented out socially) and cannot exceed 175 m² in size. (Previously the cap was 200 m² under the temporary regime.) This extends the reduced VAT to encourage urban renewal and affordable housing. [vatcalc.com]
  • Energy & Environment: Several “green” adjustments took effect in July 2025:
    • The reduced 12% VAT on coal was abolished, so coal sales are now at 21%. [kpmg.com]
    • The 6% VAT rate on the supply and installation of boilers or central heating systems using fossil fuels (e.g. fuel oil or gas burners in older homes) was withdrawn – these installations became standard-rated at 21% from 1 July 2025. This is meant to discourage fossil-fuel heating in renovations. [kpmg.com]
    • Conversely, the government announced that the VAT on heat pumps and certain renewable heating systems for newer homes would drop to 6%. In practice, for homes under 10 years old, heat pump installations temporarily became 21% in 2025 (loss of a prior concession) but will revert to 6% from 1 Jan 2026 for a 5-year period. Homes older than 10 years already enjoy 6% for such installations under the renovation rule. Essentially, from 2026 to 2030 all heat pump installations, regardless of building age, will bear only 6% VAT as a climate measure. [facq.be], [facq.be]
  • Hospitality: During the COVID-19 crisis, Belgium temporarily cut VAT on restaurant and catering services (and certain takeaway foods) to 6%. However, this reverted to 12% for restaurant food in 2022. In 2025, there is discussion on adjusting VAT for takeaway meals based on food type (e.g. some prepared meals might move from 6% to 12% if considered less basic), but as of 2026 the core rates remain 12% and 6% as described.
  • No broad rate change: The standard 21% rate hasn’t changed in decades. Belgium did not follow some neighbors in temporarily lowering the standard rate (e.g. there was no general VAT cut during COVID).

Illustrative Examples:

  • A laptop or consulting service is sold with 21% VAT (standard rate).
  • A restaurant meal (without alcohol) will have 12% VAT on the food portion, but the wine or beer is 21%. A takeaway meal or basic grocery is 6%. [fonoa.com]
  • A paperback book or an e-book download is 6% VAT (books are at 6%, whether printed or digital). [taxsummaries.pwc.com]
  • A doctor’s consultation is exempt (no VAT charged).
  • A solar panel installation on a home older than 10 years benefits from 6% as a qualifying home renovation (considered akin to energy-saving renovation). Installation on a brand new home would be 21%. (However, starting 2026, some eco-incentives might cover such cases.)
  • An export sale of machinery to a US customer is zero-rated (0% VAT) – no VAT on the invoice, but the seller can fully deduct related input VAT. [taxsummaries.pwc.com]

4. VAT Number Format

VAT Registration Number: Belgian VAT numbers have a fixed format of 10 digits preceded by the country code “BE.” They are formally the business’s company number. The first digit after “BE” is usually 0 or 1. Example: BE 0123.456.789. [fonoa.com], [avalara.com]

  • Historically, older companies had 9-digit numbers and a leading zero was added (e.g. a company number 123456789 became BE0 123 456 789). Newer companies might start with 1 (e.g. BE1 0xx xxx xxx).
  • For clarity, numbers are often written with dots: e.g. BE 0412.345.678. The official format is “BE”+10 digits with no separators.
  • The Belgian VAT number includes a check digit at the end to validate it.

When doing EU intra-community business, Belgian VAT numbers are quoted with the “BE” prefix. Belgium does not use any letters within the number itself (unlike, say, Germany or the UK in the past).

Validation: You can validate a Belgian VAT (enterprise) number via the EU’s VIES system or the Belgian Ministry of Finance website. The structure should always be 10 digits; if you see 9 digits, prefix a zero.

5. Registration Requirements

Who must register: Any person or entity performing taxable activities in Belgium may need to register for VAT. Belgium does not have a high general turnover threshold that frees regular businesses from VAT. In principle, from the first euro of taxable sales, a business should be VAT-registered – unless it qualifies for a specific exemption regime (like the small business scheme). [fonoa.com]

  • Resident small businesses: Belgium operates a VAT exemption scheme for small enterprises (“franchise de taxe / vrijstellingsregeling”) for those with annual turnover ≤ €25,000 (excluding VAT). A Belgian-established business under this threshold can choose not to register for VAT (meaning it does not charge VAT on sales, but similarly cannot deduct input VAT). This is intended to simplify life for very small traders. Important: Businesses under €25k can voluntarily register for VAT if they prefer (for example, if they have significant input VAT to recover). Many small B2B providers opt to register to reclaim VAT and appear as VAT businesses to clients. Once the €25k turnover is exceeded (in the current or prior year), registration becomes compulsory from that point. [rsm.global], [rsm.global]
  • Non-resident businesses (no Belgian establishment): A foreign company with no fixed establishment in Belgium must register for Belgian VAT as soon as it undertakes taxable activities in Belgium (there is no threshold). For example, if a Dutch company starts selling and delivering goods located in Belgium to Belgian customers, it needs a Belgian VAT number. However, if all its Belgian activities are covered by reverse-charge mechanisms (see Section 15 on cross-border reverse charge), it might avoid registration. A common case: an EU supplier selling goods B2B that are on Belgian soil can often have the Belgian customer self-account for VAT under the Article 194 reverse charge (the foreign supplier then doesn’t register). But caution: if that foreign EU supplier directly registers in Belgium (without a fiscal rep), Belgium historically disallows the reverse-charge simplification. In other words, foreign EU companies sometimes had to register and charge local VAT for certain B2B supplies if the reverse-charge didn’t apply due to Belgian rules – this is a niche point to watch. Generally, non-EU companies cannot rely on the domestic reverse-charge and must register if making any taxable supply in Belgium. [vatcalc.com], [vatcalc.com]
  • Distance sellers (e-commerce): Since July 2021, the EU’s OSS system applies – see Section 18. Essentially, if an EU retailer’s sales to Belgian consumers exceed €10,000 (combined EU-wide), they must charge Belgian VAT, but they can use the One-Stop Shop to avoid a local registration. If below that threshold, they can charge home country VAT. Non-EU e-commerce sellers can register for OSS (IOSS for imports) or appoint an intermediary; if not using IOSS, they would need a Belgian VAT registration to sell to Belgian consumers (so most opt for the OSS route). [fonoa.com]
  • Voluntary registration: Any business can choose to register even if not strictly required (e.g. a small exempt business might register to recover input VAT). Belgium imposes some conditions on non-established EU businesses who have only reverse-charged sales: they can voluntarily register if they incur > €10,000 of Belgian input VAT per year that they wish to reclaim. If below that, they’re expected to just use the EU refund process instead. [EY worldwi…tax guide | PDF]

Registration process: Belgian businesses usually register their VAT status as part of their corporate incorporation (with the Crossroads Bank for Enterprises). Non-residents must file a form (604A) to the Belgian VAT authorities to obtain a VAT number. The process for foreign companies often requires: proof of business (e.g. a certificate of VAT status from home country), identification of a responsible local contact or fiscal representative (for non-EU, see Section 8), and description of activities. Registration is typically granted fairly quickly (a few days to a few weeks once paperwork is complete).

EU One-Stop Shop (OSS): Belgium participates fully in the EU’s OSS schemes:

  • The Union OSS allows EU-based businesses to report all their B2C sales of goods and services to other EU countries through a single OSS return in their home country instead of registering abroad. For example, a Belgian webstore selling to France and Germany can charge foreign VAT and remit it via Belgian OSS returns. [fonoa.com]
  • The Non-Union OSS (for non-EU providers of services to EU consumers) and IOSS (Import OSS for distance sales of imported goods ≤ €150) are also available. These reduce the need for a Belgian VAT registration if properly used. [fintua.com]

Thresholds and special cases summary:

  • Domestic turnover threshold: €25,000 (small business exemption).
  • Intra-EU distance selling threshold: €10,000 (EU-wide). [fonoa.com]
  • Intra-EU acquisitions (for unregistered entities like public bodies): ~€11,200 per year – above that they must register to account for acquisition VAT. (This concerns non-taxable legal persons as defined; most normal businesses are registered anyway.) [vatcalc.com]
  • No threshold for foreign businesses making taxable supplies – immediate registration unless only doing reverse-charge supplies. [vatcalc.com]

6. VAT Grouping Rules

Availability: Belgium allows VAT grouping (since 2007). Under the VAT group regime, two or more persons can be treated as a single taxable entity for VAT purposes, meaning intra-group transactions are ignored for VAT.

Conditions: VAT grouping is optional and requires that the members are “closely bound by financial, economic and organizational links.” In practice, Belgium interprets this to mean:

  • Financial link: usually one company owns >10% of another (or common parent owns >10% of each). So a parent and its subsidiaries can form a group, or subsidiaries of a common parent. [vatcalc.com]
  • Economic link: the entities have related or complementary activities or a mutual economic objective.
  • Organizational link: common management or shared resources.

All three links must be present. Often, corporate groups meet these criteria readily. Holding companies: A pure holding company that isn’t VAT-taxable itself typically cannot join (since it doesn’t “carry on an economic activity”).

Procedure: Entities must jointly apply for VAT grouping. Upon approval, the group is assigned a VAT group number (often one group member is designated as the lead). The group is treated as one taxable person:

  • The group files a single consolidated VAT return covering all members. [vatcalc.com]
  • Intra-group supplies of goods or services are disregarded for VAT (no tax charged on inter-company invoices inside the group) – a big cashflow benefit.
  • All members are jointly liable for the VAT debts of the group. [vatcalc.com]

Each member will often keep its individual VAT number for identification (for example, for invoices to outside parties and for Intrastat reporting) but with an additional group suffix. For EC Sales Lists, Belgium requires listing each group member’s EU sales under sub-numbers since the customers need to see the supplier’s original VAT number. [vatcalc.com]

Exclusions: Only Belgian entities (or fixed establishments in Belgium of foreign entities) can join a Belgian VAT group. A foreign company’s Belgian branch can group with Belgian subsidiaries, but a non-established company cannot. Also, public bodies cannot form VAT groups.

Example: If Company A owns 100% of Company B and 100% of Company C in Belgium, they can form a VAT group. A supplies goods to B – normally would charge VAT, but once grouped, that supply is ignored. A, B, C collectively submit one VAT return. If A has excess input VAT and B has output VAT to pay, the credits and debits offset in the single return, possibly reducing the need for refund claims.

Pros and Cons: Grouping can significantly reduce VAT on inter-company charges and optimize cash flow. However, joint liability means if one member defaults on VAT, all others are on the hook. Also, if some members have exempt activities (e.g. finance), grouping them with others can pull down overall recovery because the whole group’s input/output calc is combined. Companies carefully evaluate if grouping is beneficial. Once in a group, typically members must stay at least until end of the calendar year (leaving too soon triggers adjustments).

In summary, VAT grouping is a useful tool in Belgium. It’s commonly used in banking/insurance groups (to consolidate exempt and taxable members) and multinational corporate structures to simplify accounting.

7. VAT Recovery for Foreign Businesses (EU 8th / 13th Directive Refunds)

Foreign businesses that incur Belgian VAT on expenses but are not VAT-registered in Belgium can recover that VAT through special refund mechanisms:

  • EU Enterprises (8th Directive refunds): If your company is established in another EU member state and you paid Belgian VAT (e.g. on hotel bills, trade show costs, local purchases), you can reclaim it via an electronic VAT refund application in your home country (the “8th Directive” procedure). You submit the claim through your national tax portal, which forwards it to Belgium. In Belgium: [vatcalc.com]

    • Refund claims can be quarterly (for Q1–Q3) or annual (Q4 or full year). Minimum claim amounts apply: typically €400 for quarterly claims, or €50 for an annual claim (these are EU standard limits). (Note: some sources indicate Belgium allows even €50 quarterly, but generally €400/€50 as per Directive.)
    • Invoices ≥ €1,000 (or ≥ €250 for fuel) must be attached as scans. Smaller invoices don’t require attachment, making it easier to claim many small receipts. [vatcalc.com]
    • The deadline is 30 September of the following year. (E.g. VAT from 2025 must be claimed by 30/9/2026.)
    • Belgium’s authorities typically respond within ~4-8 months. If approved, refunds are paid out to the foreign business’s bank account (no Belgian bank required). If questions or rejections, they communicate via the portal.
    • There is no need to appoint a fiscal representative for 8th Directive claims – you deal directly via your own tax office.
  • Non-EU Enterprises (13th Directive refunds): Companies based outside the EU, with no Belgian VAT registration, can also reclaim Belgian VAT on a reciprocal basis (the 13th Directive process). Belgium, however, is quite liberal – it does not require a reciprocity agreement for refunds. That means Belgian VAT is refundable to businesses from most countries (even if those countries don’t refund to EU firms). In practice, Belgium grants refunds to non-EU claimants from, for example, the USA, Canada, etc., without issue. Key points: [vatcalc.com]

    • The non-EU business must prove it’s a taxable business in its country. This is done by providing a “Certificate of VAT/Tax Status” from its home tax authority (an original document, often less than 1 year old). [vatcalc.com]
    • Claims are made by submitting Form VAT Refund EU 13 (paper form) to the Belgian VAT office (Foreign VAT Refund team in Brussels) by 30 June of the year following the refund year (earlier deadline than EU firms) – for example, by 30 June 2026 for 2025 VAT.
    • Original invoices or receipts must be submitted as proof (they will be returned upon request after processing).
    • Minimum claim amounts are similarly €200–€400 (depending on if annual or shorter period).
    • No Belgian fiscal representative is required for a refund claim (different from registration). The claimant can correspond directly or authorize someone to handle paperwork, but that person isn’t jointly liable – it’s not like a fiscal rep for a registration (see Section 8 for fiscal reps in registration). [vatcalc.com]
    • Refund processing may take 6–8 months or more. Interest is paid if excessively delayed.
  • Restrictions on refunds: Certain VAT is non-recoverable even via refund, mirroring rules that apply to Belgian taxpayers. For example, business entertainment expenses (client meals, hospitality) are not recoverable in Belgium – so a foreign business also cannot get that VAT back. Passenger car expenses are largely blocked (50% limit or similar, see Section 15). The refund will be denied on those items. The claimant should exclude non-deductible VAT in the application to speed processing. [vatcalc.com]

  • Notable ease: Because Belgium doesn’t demand reciprocity, companies from countries like the USA, which many EU states refuse to refund, can still get Belgian VAT refunded. Belgium is seen as quite foreign-friendly in this regard. [vatcalc.com]

In all cases, the foreign business must not be registered for VAT in Belgium (and have no requirement to be). If you inadvertently register, you’re supposed to recover VAT via returns instead, not via these refund mechanisms.

Summary: Foreign companies can recover Belgian VAT either through the EU electronic system (if EU-based) or by direct claim (if non-EU). Timely application with correct documentation is crucial. For EU claimants, using OSS or local registration might sometimes be preferable if making significant onward taxable supplies, but for one-off costs, the refund route is straightforward.

(Note: A foreign business with a Belgian VAT registration recovers input VAT through its Belgian VAT returns normally – Section 15 covers deductibility rules.)

8. Fiscal Representative Requirements

Non-EU companies often face an extra step to comply in EU countries: appointing a fiscal representative for VAT. In Belgium, the rules are:

  • EU-established businesses: If your business is based in another EU country, you do not need a fiscal representative to register in Belgium. You can register directly (direct registration) in your own name. Belgium trusts EU companies under mutual assistance regulations. [vatcalc.com]

  • Non-EU established businesses: Generally, a company with no establishment in the EU that is required to register for Belgian VAT must appoint a Belgian fiscal representative (agréé vertegenwoordiger / représentant responsable). The fiscal rep is a locally established entity or person who co-signs your VAT registration and assumes responsibility for your VAT compliance in Belgium. [EY worldwi…tax guide | PDF], [vatcalc.com]

However, there are important exceptions: Belgium waives the fiscal rep requirement for companies from certain countries that have a mutual assistance agreement with Belgium for tax recovery. Currently, this includes notably Norway (which has a special tax assistance pact) and since Brexit, the UK (Belgium allows UK companies to register directly, pending final EU-UK arrangements). In such cases, a non-EU company can do a direct VAT registration without a representative (the UK is treated leniently in the interim period). [EY worldwi…tax guide | PDF]

For all other non-EU businesses (e.g. USA, Canada, China, etc.), a fiscal representative is required to register.

Role of Fiscal Rep: The rep must be a Belgian-resident taxable person (often a Belgian subsidiary of the foreign company, or a professional firm). They jointly sign the VAT registration form and are jointly liable for VAT debts. To protect the rep, Belgium requires a bank guarantee be lodged with the treasury when appointing a fiscal rep. The guarantee typically equals 1/3 of the expected annual VAT payable (minimum €7,500, maximum €1,000,000). Since October 2021, if such a guarantee is provided, the fiscal rep is not personally liable beyond that guarantee. This makes it more attractive for firms to serve as reps. [EY worldwi…tax guide | PDF], [vatcalc.com] [vatcalc.com]

The fiscal rep handles filing VAT returns, keeping records, and responding to VAT queries on behalf of the foreign business. The VAT number legally is issued in the foreign business’s name c/o the rep.

Alternative – Global Rep for imports: Belgium also has a concept of a “global fiscal representative” specifically for handling import and onward supply situations (often used in logistics). This specialized rep (often a customs broker or forwarding agent) can act to clear goods through Belgian customs under their own global VAT number, simplifying import VAT handling for non-EU suppliers. This is beyond the standard direct registration and is used in certain distribution models.

Summary: If you are a non-EU company selling in Belgium:

  • Check if your country has a tax assistance pact (e.g. Norway, UK) – if yes, you can register for VAT directly without a rep (just like an EU company). [EY worldwi…tax guide | PDF]
  • If not, you’ll need to engage a Belgian fiscal rep. Many accounting/tax firms offer this service in Belgium. They will require a bank guarantee and charge fees.
  • Once in place, you’ll get a Belgian VAT number (often the rep’s number with a unique suffix) and the rep will ensure compliance.

Example: A U.S. company selling software to Belgian customers must register for VAT (since electronic services to consumers require local VAT after €10k EU-wide). Because the U.S. has no mutual VAT pact, the company appoints a Brussels-based accounting firm as its fiscal rep. They arrange a €10,000 bank guarantee and file Form 604A. The VAT number BE0XXXXXXXX is issued. The U.S. company charges Belgian VAT and the rep files the returns. Later, if the U.S. company stops Belgian activities, the rep can help deregister and the guarantee is released once all obligations are settled.

9. Currency and FX Rules

Belgian VAT must be reported in EUR. If an invoice is issued in another currency, the VAT amount should be converted to euros for reporting. Key rules:

  • When converting foreign currency amounts to EUR for VAT purposes, Belgium accepts the use of the official exchange rates. In practice, businesses typically use the European Central Bank (ECB) rate or the rate published by the National Bank of Belgium for the date of the supply. The Belgian VAT Code permits either as long as it’s applied consistently. [vatcalc.com]
  • On VAT invoices in foreign currency, it’s required to state the VAT amount in EUR (or at least provide a conversion). E.g. a supplier billing in USD should show “VAT = €X (converted at rate on date)”. This ensures the VAT is clear in local currency.
  • If transactions are recorded in accounting in another currency, for VAT returns they must be translated to EUR. Companies often use end-of-period ECB rates for simplicity, but the tax authority can ask that the transaction-day rate be used for precision. Consistency is key.
  • Belgium does not impose a specific fixed conversion source by law (some countries mandate ECB monthly rate or customs rates – Belgium allows either ECB or Belgian central bank’s official rate, which are usually almost identical). The ECB daily rate is a common choice since it’s easily accessible. [vatcalc.com]
  • Example: A Belgian company receives a supplier invoice of USD 1,000 + VAT from a non-EU provider who somehow charged Belgian VAT. The Belgian VAT should be converted: if ECB rate that day was 1 € = 1.10 USD, the supplier would state “VAT = €…”. On the VAT return, that EUR amount is what gets declared.

In summary, Euro is the VAT currency. Conversion should use reliable official rates (ECB or NBB). This is in line with EU rules that allow using the European Central Bank’s rate or the locally published rate. Businesses should document the rate used (e.g. keep a copy of the rate source) in case of audit.

10. VAT Law and Legal Framework

Belgium’s VAT system is governed by:

  • The Belgian VAT Code (Code de la TVA / BTW-Wetboek), which is the primary law detailing VAT scope, rates, exemptions, obligations, etc. It closely follows the structure of the EU VAT Directive.
  • Royal Decrees (Koninklijke Besluiten / Arrêtés Royaux) and Ministerial decrees, which provide implementing rules. For example, Royal Decree No. 1 covers VAT registration and invoicing rules; Royal Decree No. 57 covers use-and-enjoyment provisions for transport (see Section 15).
  • Periodically, the tax administration issues circulars and rulings giving guidance on interpretation. While not laws, they are important for practical compliance.

EU Law Primacy: As an EU member, Belgium’s VAT law is aligned with the EU VAT Directive 2006/112/EC. In case of any conflict, EU law prevails. Belgian courts and the administration refer to EU legislation and Court of Justice (ECJ) case law when interpreting VAT issues. For example, the Belgian VAT Code’s Article 44 exemptions mirror those in the Directive Annex III, etc..

Notable features of Belgian VAT law:

  • It contains options offered by the Directive: e.g., option to tax immovable rentals (since 2019), use and enjoyment rules for certain services (transport – see Section 15), special schemes like margin scheme for second-hand goods, flat-rate for farmers, etc., which are implementable under EU law.
  • It also has some unique compliance rules, like the annual client listing (listing domestic B2B customers – see Section 23) that go beyond EU requirements.

Administration and Enforcement: VAT is administered by the FPS Finance – VAT department (Administration de la TVA / BTW Administratie). They have powers to audit, request information, impose penalties (see Section 24). Belgian VAT law provides a standard statute of limitations of 3 years for audits, extended to 7 years for certain cases (e.g. intra-EU transactions – see Section 21). [vatcalc.com]

Integration with other laws: The VAT Code is separate from income tax laws, but cross-references exist (like definitions of enterprise). Also, since Belgium is federal, VAT is uniform nationally (regions don’t have separate VAT rules, unlike some other taxes).

In essence, Belgian VAT law = EU Directive implemented, with local nuances. Businesses typically rely on the VAT Code (and its annexes) plus guidance from the VAT Handbook (admin’s commentary) for detailed application.

11. Tax Authorities

The Belgian Tax Authority responsible for VAT is the Federal Public Service (FPS) Finance, particularly its General Administration of Taxation (Algemene Administratie van de Fiscaliteit / Administration Générale de la Fiscalité). Within this, a dedicated VAT Administration handles indirect tax. Key points: [fonoa.com]

  • Organization: There are local tax offices (“Controles TVA / BTW-controles”) throughout Belgium (often one per district or per group of districts) that handle VAT registrations, declarations, and audits for taxpayers in their area. For large companies, specialized units exist. There’s also a Central VAT office for foreign traders in Brussels that deals with non-resident VAT registrations and refund claims.
  • Contact and Services: The FPS Finance provides information through its website (finance.belgium.be – available in French, Dutch, German, English), helplines, and local enquiry desks. Many processes (registration changes, filings, certain rulings) are moving online via the MyMinfin portal.
  • Audits and Enforcement: The VAT authority conducts audits both desk-based (via correspondence) and on-site. It also uses data matching (e.g. VIES cross-checks of EC sales listings) to detect discrepancies. Notably, Belgium requires an annual client listing which it compares with customers’ filings as a compliance tool.
  • Appeals: Taxpayers can contest VAT decisions via an administrative appeal to the Regional Director of VAT, and subsequently to the courts (first instance is Tribunal of First Instance). The system ensures judicial review of VAT disputes.
  • VAT Authority divisions: Belgium’s indirect tax officials might also oversee related duties like excise or environmental taxes, but VAT is the largest component.

Tax Authority’s approach: Belgium’s VAT administration is considered generally pragmatic and business-oriented (the country has a history as a trade hub). They offer advance rulings through a separate Ruling Commission (Service des Décisions Anticipées) for tricky VAT questions – e.g. complex lease arrangements, digital economy questions. This provides certainty if sought.

The tax authority also engages in EU-level cooperation. For example, Belgian VAT inspectors participate in Eurofisc to fight cross-border fraud. They will cooperate with other EU countries on audits of, say, carousel fraud.

Language: Tax correspondence can typically be in Dutch or French depending on the region (Dutch in Flanders, French in Wallonia, and both in Brussels). However, they will accommodate English for many things involving foreign businesses. Official forms are often bilingual.

In summary, the FPS Finance – VAT Department is the entity to deal with for all VAT matters – from getting your VAT ID, filing returns, to handling audits or refunds. Keeping good relations and prompt compliance with their requests will ease a business’s VAT life in Belgium.

12. Scope of VAT

Transactions subject to VAT: In Belgium, as in the EU, the following are within the scope of VAT (if performed for consideration by a taxable person): [taxsummaries.pwc.com]

  • Supplies of goods in Belgium – i.e., the transfer of the right to dispose of tangible property. If you sell goods and the sale is deemed to take place in Belgium (e.g., local sales, or installation of goods here), it’s taxable.
  • Supplies of services in Belgium – essentially any transaction that is not goods. This covers a broad range: consulting, transport, catering, digital services, etc., when the Belgian VAT rules consider Belgium the place of supply.
  • Intra-Community acquisition of goods in Belgium – goods moving to Belgium from another EU Member State, acquired by a VAT-registered person. Such acquisitions (B2B purchases) are taxed in Belgium (the purchaser self-accounts via the reverse charge on their return). [taxsummaries.pwc.com]
  • Importation of goods into Belgium – goods brought in from outside the EU customs territory are subject to Belgian import VAT (usually collected by customs). [taxsummaries.pwc.com]
  • “Deemed” supplies and self-supplies: e.g., taking goods out of stock for private use, or transferring own goods cross-border under certain conditions, can be taxed to prevent avoidance. [taxsummaries.pwc.com]
  • Purchase of certain services from abroad (B2B) – under the reverse charge rule. If a Belgian VATable business buys services from a foreign provider (e.g. consulting from a US firm), Belgium treats it as if the Belgian is both receiving and making the service in Belgium, thus VAT is due (reverse-charged). [taxsummaries.pwc.com]

To fall within VAT, a supply must be made by a “taxable person” in the course of business. Taxable persons include companies, self-employed individuals, partnerships, etc., carrying on economic activities. Non-taxable legal persons (like NGOs not engaged in economic activity) aren’t usually in scope when they, say, grant something for free.

Territorial scope: VAT applies in the territory of Belgium, which includes the Belgian mainland and territorial waters, but excludes certain duty-free zones (none significant for VAT except embassies etc. which have special status). There are no domestic variances – the whole country is one VAT area. (Overseas: Belgium has no territories outside Europe.) Intra-EU, the concept of intra-Community supply/acquisition applies.

Common exempt or out-of-scope situations: If a transaction is exempt (Section 3), it’s outside the tax base (though often still within “scope” but with exemption). If it’s not for consideration (true free gift not in context of business promotion above thresholds, or a subsidy not linked to price), it might be outside scope.

Place of supply rules: These determine whether a supply is considered “in Belgium” or not:

  • Goods: Generally where the goods are located at time of sale. If sold and delivered in Belgium, VAT applies. If shipped cross-border:
    • B2B intra-EU: if goods leave Belgium to another EU country, it’s a Belgian zero-rated intra-Community supply and taxed as an acquisition in the other country.
    • Imports: goods from outside EU enter Belgium – Belgian import VAT.
  • Services: Belgium follows EU place-of-supply rules:
    • B2B services are taxed where the customer is established (so foreign B2B services to Belgian businesses are in-scope in BE via reverse charge; Belgian services to foreign business are out of BE scope). [taxsummaries.pwc.com]
    • B2C services are usually taxed where the supplier is (so foreign consumer buying from a Belgian, Belgium would tax – though the foreign consumer might owe no VAT if outside EU in some cases). Many exceptions apply (for real estate, events, transport, ESS, etc. per EU rules).
    • Notably, electronically supplied services to EU consumers are taxed in the consumer’s country – thus to Belgian consumers (via OSS, see Section 17).

Examples in scope:

  • A Belgian company sells chocolates to a local individual – Belgian VAT due (21% on chocolates, or 6% if qualifying food basics).
  • A French company ships goods to a Belgian private customer (distance sale) – once threshold passed, Belgian VAT due (OSS mechanism).
  • A US consultant provides advice to a Belgian firm – Belgian VAT is due under reverse-charge (place of supply B2B is Belgium because customer is here, so the Belgian client must self-account). [taxsummaries.pwc.com]
  • A Belgian architect designs a building in Belgium for a German business – Belgian VAT applies (because the service is related to Belgian immovable property, place of supply is Belgium, so the Belgian architect charges VAT).
  • A UK firm gives a training in Brussels to the general public – Belgian VAT (admission to event in BE).
  • A Belgian company gives away promotional samples of soap (under conditions) – this is considered a deemed supply; small samples for business promotion can be zero-rated up to a point, but beyond that, self-supply rules may tax it.

Outside scope vs exempt:

  • Selling used equipment privately (not as a business) is outside VAT’s scope (not an economic activity).
  • A purely free-of-charge service between two distinct entities with no benefit might be outside scope (though often mutual supplies are seen as barter).
  • Government activities in their sovereign capacity (non-economic, like issuing passports) are outside VAT.

To summarize, VAT applies widely to economic sales of goods/services in Belgium. Exceptions are defined by law (exemptions) and place-of-supply rules push taxation to the correct jurisdiction. If you’re doing business in Belgium for consideration, it’s likely within VAT scope unless specifically exempted.

13. Time of Supply Rules (Tax Point)

The time of supply (tax point) defines when VAT becomes chargeable to the tax authorities. Belgium’s rules align with EU principles, with some national specifics:

General Rule – Goods & Services: VAT becomes due at the time when the goods or services are supplied or when an invoice is issued or when payment is received – whichever comes first, subject to a latest deadline. In practice: [EY worldwi…tax guide | PDF]

  • If an invoice is issued, the invoice date is the tax point. [EY worldwi…tax guide | PDF]
  • If no invoice is yet issued by a certain cutoff, then the 15th of the month following the supply is the tax point by law. (EU rule: you must invoice by the 15th of the next month for B2B, so VAT is due at that latest date even if no invoice). [EY worldwi…tax guide | PDF]
  • If a payment (advance) is received before the supply/invoice, then VAT on that amount becomes due at the time of payment. [EY worldwi…tax guide | PDF]

Belgium explicitly states: if a payment is received before goods are put at buyer’s disposal or service completion, that triggers VAT for the amount paid, provided the goods/service can be clearly identified. So advance invoices carry VAT immediately. [EY worldwi…tax guide | PDF]

Exception: Intra-Community supply of goods – Belgium follows the EU rule that no VAT is due on prepayments for cross-border EU goods. VAT on an intra-EU sale is only due when the supply (shipment) happens, not on earlier payments. [EY worldwi…tax guide | PDF]

Continuous supplies of services: For continuous or ongoing services (without individual completion moments), Belgium requires VAT be accounted at least once a year. If periodic invoices are issued (e.g. monthly or quarterly billing for ongoing service), each invoice creates a tax point. If no periodic invoices, then on December 31 each year a tax point is deemed to occur for the portion of services rendered up to that date. This ensures things like long-term rentals or maintenance contracts are taxed at least annually if not more frequently. [vatcalc.com]

Importation of goods: Import VAT is due at the moment of import (customs clearance). Belgium allows import VAT deferment (see Section 15) which effectively shifts the accounting to the monthly return, but strictly the tax point is when goods enter free circulation. If deferred, the tax point is the period of the import (for which you include it in that return). [vatcalc.com]

Goods on approval / sale or return: If goods are sent to a customer on a “try before buy” basis, the VAT point arises when the customer actually approves/purchases the goods or after the agreed trial period if not returned. Under EU rules (which Belgium follows), a sale or return is treated as supplied when the customer takes ownership (implicitly or explicitly). So if a gallery sends artwork to a client “on approval” for 30 days, the VAT triggers only when the client decides to buy or at day 30 if they keep it. If returned, no sale occurred (no VAT).

Special cases:

  • Vouchers: For single-purpose vouchers, VAT is due on sale of the voucher (since the tax point is that sale). For multi-purpose vouchers, VAT is due when redeemed. (Belgium follows the 2019 EU voucher rules – not elaborated here, but noteworthy.)
  • Installment payments: Each installment creates a tax point for that portion when invoiced/received.
  • Invoicing deadline: As noted, a key anchor is that an invoice must be issued by the 15th of the month following supply for B2B supplies. So even if neither goods delivered nor payment occurred (which is rare), that date would force a tax point. Practically, the earlier of supply or invoice covers it.
  • Delivery spanning months: If a service is delivered over say March-April and one invoice covers it in May, by EU rules tax point is May 15 (assuming supply done by April 30 and invoice by May 15). If invoice delayed beyond May 15, VAT would still be due by May 15.

Examples:

  • A consulting firm completes a job on 10 March and issues an invoice on 5 April. Tax point = 5 April (invoice date), so it goes in the April VAT return. [EY worldwi…tax guide | PDF]
  • Same scenario but invoice issued 30 March: tax point 30 March.
  • If invoice isn’t issued until 30 May (late), technically VAT was due by 15 April (15th of month after supply). The firm could be penalized for late accounting. [EY worldwi…tax guide | PDF]
  • A customer pays a 50% deposit on a machine in June (before delivery); that 50% triggers VAT in June. The balance is paid on delivery in August – that triggers remaining VAT in August. [EY worldwi…tax guide | PDF]
  • A lease of equipment for 3 years with quarterly rent: each quarterly invoice is a tax point (end of March, June, etc.). If it were an open-ended lease with no periodic billing, at least every 12 months a self-billing should occur (usually businesses do invoice periodically to avoid confusion).

Accounting implications: Businesses must declare output VAT in the period of the tax point. Missing the correct period (e.g. forgetting to declare an advance) can lead to interest. It’s crucial to align invoicing and receipts with VAT returns.

Belgium’s rules are essentially: “Invoice or pay, then pay (the VAT)” – earliest event of invoice issuance or payment receipt causes the tax to be due, with a backstop of the 15th of next month if neither comes first. Continuous supplies ensure no indefinite delay (yearly at minimum). [EY worldwi…tax guide | PDF] [vatcalc.com]

This is very much in line with the EU VAT Directive Article 66 and 64.

14. VAT Invoicing Requirements

Belgian VAT law lays out detailed invoicing requirements in terms of when invoices must be issued, what information they must contain, special invoice types (e-invoices, simplified invoices, self-billing), how long to keep them, and how to correct them.

Invoice Issuance (Timing)

  • B2B and Export Supplies: For supplies to other businesses or exports, an invoice is mandatory. It must be issued no later than the 15th day of the month following the month of supply. (This aligns with EU rules.) In practice, most businesses invoice immediately at delivery or month-end, but this is the legal latest. For continuous services or long projects, at least interim billing by that deadline is required. [vatcalc.com]
  • B2C Supplies: In principle, invoices are not required for retail sales to private consumers (except in certain cases like distance sales or if the customer requests one). Instead, a receipt is often given. However, many B2C businesses issue invoices anyway for record. If an invoice is issued to a consumer, it should follow the normal content rules.
  • Requirement to Invoice: Some B2C must invoice: e.g. distance sales (online sales) and new vehicle sales to consumers require VAT invoices. Also, if a private customer asks for an invoice (commonly for construction works on their house, etc.), the supplier must provide it.
  • Self-billing situations: If the customer issues the invoice on behalf of the supplier (self-billing, see below), an invoice is still considered issued in time if by the 15th of next month.
  • Credit notes (invoice corrections) should be issued without undue delay once an adjustment is agreed.

Required Invoice Contents

Every VAT invoice in Belgium (whether paper or electronic) must include certain information as per Article 5 of Royal Decree No. 1 and EU Directive Article 226: [fonoa.com], [fonoa.com]

  1. Date of issuance – the invoice date. [fonoa.com]
  2. Unique sequential number – Invoices must be numbered sequentially (it can have multiple series, but within a series no duplicates). [fonoa.com]
  3. Supplier information: Full name (or business name), address, and VAT identification number of the supplier. [fonoa.com]
  4. Customer information: Full name (or business name), address, and VAT number of the customer if the customer is taxable or an organization with a VAT number. For B2C with no VAT number, an address is often still included except for very simplified receipts. [fonoa.com]
  5. Description of goods or services: and their quantity/extent. (Clear description so it’s identifiable what was supplied.) [fonoa.com]
  6. Date of supply (date of delivery of goods or completion of services) if different from invoice date. (This is required especially if supply and invoice fall in different months.) [fonoa.com]
  7. Net unit price (price per item or unit excluding VAT), any discounts or rebates if not included in the unit price. [fonoa.com]
  8. Taxable amount per rate – i.e., the net sum to which each VAT rate applies. [fonoa.com]
  9. VAT rate(s) applied – e.g. 21%, 12%, 6% – and for each rate the corresponding VAT amount in euros. [fonoa.com]
  10. If an exemption or reverse charge applies, a reference to the applicable provision. For instance, if it’s an intra-Community supply: mark “Exempt – Article 39bis VAT Code” (or EU Dir art. 138). If domestic reverse charge (like construction services to a VAT-registered developer), mention “Reverse charge – art. 51 §2 5° VAT Code” (and no VAT charge). If small business regime (no VAT), mention “Exempt – small enterprise regime, art. 56bis”.
  11. Total amount payable including VAT, in EUR. [vatcalc.com]
  12. Special mentions: If a self-billing arrangement, invoice must state “Self-billing” and reference the agreement. If a fiscal representative issues it, mention on whose behalf. If it’s a margin scheme (second-hand goods), mention “Margin scheme – second-hand goods” (no VAT shown). [fonoa.com]
  13. Fiscal rep details: If applicable, the name, address, and VAT number of the fiscal representative should appear (for foreign entities operating via a fiscal rep). [fonoa.com]
  14. If currency other than EUR is used on invoice, show VAT amount in EUR (with conversion rate or at least clearly converted) as noted in Section 9.

In practice, most invoices show a breakdown like: net amount, VAT % and amount, and gross total. Also commonly invoice will show supplier’s bank account, payment due date, etc. (though those aren’t legally mandated by VAT law).

Electronic Invoices: Belgium fully recognizes electronic invoicing under EU rules. An e-invoice must contain the same data and ensure authenticity of origin, integrity of content, and legibility over time. This can be achieved by advanced electronic signature, EDI with agreement, or other business controls. Digital signatures are not mandatory by law, but often used. As of 2026, e-invoicing will be mandated for B2B (see Insight box above) – invoices will then generally be in structured format (Peppol UBL). Even then, the content requirements remain, just in XML fields. [vatcalc.com]

Simplified Invoices (Receipts): For retail or small transactions ≤ €100, a simplified invoice (like a cash register receipt) may be issued. These need fewer details – often no customer name, and possibly aggregated VAT info. Simplified invoices are not allowed for B2B intra-EU supplies or exports – full invoices are needed in those cases. Also, certain sectors (like cafes, restaurants) use certified registered cash till receipts which are accepted as simplified invoices to consumers. These still must show: date, seller info, item description or generic, VAT breakdown by rate or a statement “VAT included X%”. [vatcalc.com]

Self-Billing: If the customer issues the invoice on behalf of the supplier (common in some industries or intercompany charges), there must be a prior agreement between the parties. The invoice must state “Self-billing – agreed by supplier” (or equivalent wording). The supplier must accept each invoice (even implicitly, e.g. by not disputing it). Self-billed invoices have the same required content. The agreement and process must ensure no duplicate invoicing. [vatcalc.com] [fonoa.com]

Retention of Invoices: Businesses must keep copies of all issued and received invoices (and credit notes) for at least 7 years from the end of the year to which they relate. For capital goods (immovable property), the retention is 10 or 15 years (to cover the adjustment period). In 2023, Belgium extended the general retention period to 10 years for all invoices, aligning with audit periods – so practically invoices should now be kept 10 years. Storage: They can be kept in electronic form (e.g. scanned or original PDF) as long as they are easily accessible and unaltered. If kept purely electronically, there must be a way to reproduce them on paper if needed. Original paper invoices should be kept in Belgium unless digitized according to standards, whereas electronic invoices can be stored anywhere as long as online access can be given to Belgian authorities on request. [vatcalc.com]

Invoice Corrections (Credit/Debit Notes): To correct an invoice (e.g. if an overcharge or a return), a credit note (avoir / créditnota) should be issued. It must cross-reference the original invoice (invoice number and date) and state the reason for credit (e.g. “return of goods,” “discount adjustment”). The credit note shows negative amounts for the VAT being adjusted. This allows both supplier and customer to adjust their VAT accounts. If undercharged initially, a debit note or additional invoice would be issued likewise. Belgian law requires such correcting documents to contain essentially the same info as invoices (just negative or additional values) and they form part of the accounts. A credit note is how you formally adjust VAT after an invoice is issued – simply short-paying an invoice isn’t enough; the VAT declared needs a credit note to back the adjustment in the VAT return. [vatcalc.com]

Special Cases:

  • Exempt or Reverse-Charged invoices: Must mention the reason for not charging VAT (as noted above). A common phrase for domestic reverse charge: “BTW verlegd – art. 51 §2, 5° W.BTW” (Dutch) or “Autoliquidation – art. 51 §2, 5° Code TVA” on the invoice.
  • Large invoice amount: If invoice is exceptionally large, breakdown by line with VAT per line isn’t mandatory, but summary per rate must be clear.

Belgian VAT takes invoicing seriously, as invoices are the fundamental evidence in VAT deduction and audits. As such, compliance with invoicing rules is strictly monitored. Missing required fields (VAT number, etc.) can lead to administrative fines (usually €50–€500 per infraction).

E-invoicing Mandate 2026: From 2026, all B2B invoices between Belgian VAT taxpayers must be electronic (structured format). While legislation is in place (pending EU derogation), businesses should prepare to shift from paper/PDF to XML (Peppol network). The core content requirements remain the same – only the medium changes. There is no requirement to send invoices to the tax authority in real time (no clearance), just business-to-business via an approved platform. The aim is to make compliance more efficient and reduce fraud (as e-invoices are harder to forge and easier to track).

In summary, Belgian VAT invoices must be timely, complete, and preserved. This ensures input VAT will be deductible by customers and protects the supplier in case of audit.

15. Compliance and Deductions

This section covers various compliance rules and specific deduction policies: how input VAT can be deducted, special stock arrangements, reverse charge mechanisms, treatment of discounts and bad debts, import VAT deferral, VAT warehousing, “supply & install” scenarios, use-and-enjoyment rules, and capital goods adjustments.

Right to Deduct Input VAT (and Key Exceptions)

Basic rule: A VAT-registered business in Belgium can deduct (reclaim) the VAT paid on purchases of goods and services to the extent those purchases are used for its taxable business activities. Deductions are made on the periodic VAT return, offsetting output VAT.

However, some input VAT is not deductible (either fully or partially) by law – these are essentially cost items where VAT is blocked as it often corresponds to personal consumption or exempt activities. Notable Belgian non-deductible VAT items: [vatcalc.com]

  • Entertainment expenses: VAT on business entertainment (taking clients to restaurants, receptions, hospitality events) is not recoverable. This includes VAT on restaurant meals, drinks, shows, etc. incurred for business contacts. (Contrast: if the expense is passed on to a client and taxed, that’s different – but pure biz entertainment is blocked.) [vatcalc.com]
  • Accommodation and food for employees: VAT on hotel stays, meals, beverages for staff travel is generally not deductible unless the expense is incurred in the direct needs of providing a service. (E.g. an out-of-town contractor’s hotel might not be deductible if seen as personal need, though in practice many companies do recover travel VAT if for business trips abroad; domestic representation is blocked.) Belgium specifically lists lodging and meals (except for certain travel service providers) as non-deductible. [vatcalc.com]
  • Car expenses: Belgium restricts input VAT on passenger cars. 50% of the VAT on car purchase, lease, fuel, and maintenance is typically non-deductible (only 50% can be reclaimed, even if car is 100% business use). This is a flat restriction to account for possible private use. (Commercial vehicles like trucks/vans not designed for passenger transport are fully deductible.) [vatcalc.com]
  • Fuel for cars: same 50% rule generally. Some specific cases like fuel for certain machinery is fully deductable, but for standard company cars, half blocked.
  • Business gifts: VAT on gifts to customers or contacts is non-deductible if the gifts are above €50 in value per recipient per year. Small promotional items below €50 (with company logo, etc.) can be treated as deductible (and output VAT self-assessed if needed – Belgium aligns with EU minimal threshold for gifts). [vatcalc.com]
  • Non-business (private) use: If goods/services are used for private purposes or non-business use, the related VAT is not deductible (or must be proportionally reduced). E.g. if a company buys a laptop and it will be used 30% for the director’s personal use, only 70% of VAT is deductible.
  • Exempt activities: If a business has some exempt without credit activities (like banking), input VAT related to those is not deductible. This is handled via pro-rata calculations. For example, a company doing 50% taxable and 50% exempt turnover can only deduct ~50% of its mixed expenses’ VAT. Belgium follows the EU pro-rata rules. Some input VAT can be directly attributed to taxable vs exempt streams; common overhead gets prorated.
  • Telecom use – private vs business: Historically some telephone (mobile/landline) VAT was only partly deductible if personal use was involved (similar to cars).
  • Specific items: VAT on restaurant meals is generally non-deductible (treated as entertainment unless traveling staff? Typically blocked), representative clothing not part of uniform, etc., is not deductible.

Belgian law essentially enumerates these exceptions in Article 45 §2 of the VAT Code.

A taxable person should only deduct VAT on costs that truly serve the taxed business operations. If an item serves both taxed and exempt operations, a proportional deduction is done. If it serves taxed and personal use, only the business portion’s VAT is deductible (and a self-supply output VAT may apply for the private use remainder – e.g., company assets used privately trigger output VAT on that use, or one adjusts deductions accordingly).

Deduction procedure: Input VAT is deducted on the VAT return of the period in which the supplier’s invoice is dated (or when import VAT is paid). The business needs to hold a valid VAT invoice to support the deduction (with the supplier’s VAT number, etc.). If an invoice lacks mandatory info (like VAT number or has errors), the deduction can be denied until corrected.

Any non-deductible VAT becomes a cost to the business (often recorded as an expense in accounts). Businesses must keep documentation showing how they determined their deductible percentages (especially if partial exemption).

Call-Off Stock Arrangements

Call-off stock refers to inventory sent to a customer’s location (or nearby warehouse) but still owned by the supplier until the customer “calls off” (withdraws) the stock. Prior to 2020, such arrangements caused tricky VAT registration issues in many countries.

In Belgium:

  • Historically, Belgium had a local simplification for consignment stocks: If a foreign EU supplier kept call-off stock at a Belgian customer’s premises, they could avoid Belgian VAT registration under certain conditions (the customer did a self-acquisition). This was an administrative tolerance.
  • As of 2020, the EU “Quick Fixes” introduced a harmonized call-off stock simplification (Article 17a of Directive). Belgium implemented this. Now, if an EU supplier moves goods to Belgium under a call-off arrangement with a known customer who will take title within 12 months, no VAT is due on arrival and the foreign supplier need not register. The eventual sale is treated as an intra-EU supply from the supplier’s country to Belgium (when call-off happens) and an acquisition by the customer in Belgium. [vatcalc.com]

What this means: A foreign supplier (from another EU state) can maintain a stock in Belgium for one specific customer, and when the customer pulls items, the supplier issues an EU invoice zero-rated, customer self-charges Belgian VAT as an intra-community acquisition. The supplier doesn’t have to have a Belgian VAT number. The arrangement must be pre-agreed and the goods must be taken by that customer within 12 months of arrival. If not taken in 12 months, it’s deemed supplied (and would trigger VAT and likely require registration). [vatcalc.com]

Belgium updated its law accordingly. They also keep records: both supplier and customer must record these movements in a special ledger or listing (this is part of EC Sales List reporting as well – the supplier’s ESL includes a special call-off code, and the customer lists acquisition when it happens).

If the conditions for the call-off simplification are not met, then the foreign supplier might need to register and handle it as a domestic supply in Belgium.

This simplification “eases registration requirements”: [vatcalc.com]

  • “VAT registration requirement eased for non-residents with imports or intra-community supplies into Belgium to a single customer’s site under their control,” as vatcalc summarized. [vatcalc.com]
  • The goods must be transferred or returned within 12 months, otherwise fallback rules apply. [vatcalc.com]

Domestic call-off: If a Belgian supplier stores goods at a Belgian customer’s location, VAT doesn’t arise until the transfer of ownership (that’s just normal supply timing). So call-off is mainly an issue cross-border.

In short, Belgium follows the EU call-off stock harmonized rule: no immediate VAT on transfer of own goods into BE if destined for a known customer, sale within 12 months. This avoids foreign companies having to get Belgian VAT numbers for such consignment arrangements. [vatcalc.com]

Reverse Charge Mechanisms (Domestic and Cross-Border)

Cross-border reverse charge (Article 194 of Directive / Article 51 §2 5° of BE VAT Code): Belgium applies a general B2B reverse charge for foreign suppliers not established in Belgium supplying taxable goods or services in Belgium to a Belgian taxable customer. In practice:

  • If a foreign company with no Belgian establishment sells goods located in Belgium or provides services where Belgium is the place of supply, and the customer is a Belgian VAT-registered business (or a foreign with fiscal rep), then the customer must self-account for the Belgian VAT. The foreign supplier does not charge Belgian VAT.
  • This even applies if the foreign supplier is itself Belgian VAT-registered in some cases, as long as they have no fixed establishment in Belgium (unusual scenario: e.g., a Dutch company took a BE VAT number for some reason but has no BE establishment – even then, it can invoice BE customers without VAT under reverse charge).
  • Important quirk: Belgium historically restricted this if the foreign supplier was directly registered (without a fiscal rep) – Belgium would say the foreign supplier “is identified in Belgium” and thus reverse charge wouldn’t apply unless the customer had a fiscal rep. Simplifying: to use reverse charge, the Belgian customer must be (a) established in Belgium or (b) has a Belgian fiscal rep. If the Belgian customer is only VAT-registered via direct identification (like a foreign business with just a VAT number), Belgium did not allow reverse charge. This is an unusual strictness in Belgian law intended to force some foreign entities to get fiscal reps.
  • On such reverse-charged invoices, the supplier should mention “VAT reverse-charged to recipient, art. 51 §2, 5° Belgian VAT Code”. The customer then accounts for VAT in their return (output and input, net zero if fully deductible).
  • This rule covers most services (B2B general rule ones) and also goods delivered within Belgium by a non-established supplier. It was originally optional under EU law (Article 194), but Belgium implemented it broadly.

Domestic reverse charge (certain sectors): Belgium has several domestic reverse charge mechanisms where the customer must account for VAT, to combat fraud:

  • Construction work: Supplies of construction work on immovable property (and related labor) by a subcontractor to a VAT-registered contractor or developer are reverse-charged. The customer in Belgium (the contractor) pays the VAT. This prevents missing trader fraud in construction. (Applies if both supplier and recipient are VAT taxable and the recipient is registered.)
  • Sale of certain waste and scrap materials: Reverse charge on supplies of scrap metal, waste, certain recyclable materials – customer accounts for VAT.
  • Raw gold, investment gold: Industrial gold (non-monetary) B2B sales often reverse-charged by law. [vatcalc.com]
  • Gas, electricity, greenhouse gas emission allowances when supplied to a taxable dealer – reverse charge (as per EU provisions).
  • These domestic reverse charges are all implemented in Belgian VAT Code Article 20 and 21 and Royal Decree No. 1. The supplier must mention the relevant article and not charge VAT.

Call-off stock scenario: The cross-border movement part is not invoiced (no VAT as explained). When the customer draws the goods, it’s treated as an intra-EU supply (supplier zero-rates) and an intra-EU acquisition by the customer, not a domestic reverse charge per se. The customer accounts for acquisition VAT (similar effect as reverse charge).

Import reverse charge: Belgium allows import VAT deferment to the return (see below). That is sometimes referred to as a “reverse charge on import” because the importer can self-account for import VAT instead of paying at border. Businesses with authorization can declare import VAT in their periodic return (thus output/import VAT and input VAT offset). This is extremely useful for cash flow (no actual payment). Belgium’s ET 14.000 license is the import deferral scheme (common in Netherlands too). [vatcalc.com]

Summary: In Belgium, if you’re a Belgian business buying:

  • Services from a foreign firm → likely you reverse charge (self-account for VAT). [taxsummaries.pwc.com]
  • Goods within Belgium from a non-resident supplier → you likely reverse charge (so long as you’re VAT registered and supplier has no BE fixed establishment).
  • Certain domestic goods/services (construction, etc.) from any supplier → you may have to reverse charge by law (supplier will indicate this).

This simplifies compliance for suppliers and protects revenue (shifts liability to buyer who is known to tax authorities).

Cash Discounts

Cash discounts (for prompt payment) are common in trade. Belgium’s VAT treatment: if a cash discount is taken by the customer, the VAT taxable amount is reduced accordingly. No separate credit note is required solely for taking an early payment discount. [vatcalc.com]

For example, invoice €1,000 + VAT 21% with 2% discount for payment within 10 days. If customer pays within 10 days, they pay €980 + VAT €205.8 (i.e. 2% off base and VAT). The supplier can simply report €980 as taxable and €205.8 as VAT. Historically, Belgian law allowed not having to issue a credit note for the discount difference – the initial invoice can state “2% discount for early payment” and the customer can short-pay that amount. The supplier then adjusts the VAT in its accounts automatically. [vatcalc.com]

If the invoice was already recorded fully and customer later takes the discount, the supplier can reflect the adjustment in the VAT return of that period. Many companies will just issue an adjusted invoice or credit note for clarity, but legally not required if the discount terms were on the original invoice. [vatcalc.com]

Thus, cash discounts reduce the taxable amount and the VAT due is on the net amount actually paid. This aligns with the EU concept that subsequent discounts reduce the taxable base under Article 90 VAT Directive.

If a discount is not taken (customer pays full amount after due date), then no adjustment – the original VAT stands.

Trade discounts (on invoice) are handled by including them in the invoice calculation (net of discount). Year-end rebates or bonuses beyond invoice (retroactive discount) usually require a credit note.

Bad Debt Relief

When a customer does not pay and a receivable becomes a bad debt, Belgian law allows the supplier to adjust (recover) the VAT that was paid on that sale, under certain conditions:

  • The supplier must demonstrate that the debt is definitively uncollectible – typically by showing the customer’s bankruptcy, court recognition of insolvency, or exhaustive collection attempts. Simply delay in payment is not enough; it must be a clear bad debt (e.g. debtor gone bankrupt or proven insolvency). [vatcalc.com]
  • Once confirmed, the supplier issues a credit note to itself (internally) to adjust the output VAT previously declared. In practice, one adjusts the VAT via the return. Belgian practice is to make an adjustment in the VAT return when the bad debt is established.
  • Timing: It can be done when the debtor is declared insolvent or after certain period of non-payment with evidence of attempts. Typically, if a client goes bankrupt, VAT on their unpaid invoices can be reclaimed in the period of bankruptcy declaration.
  • There is a statute of limitations: The adjustment claim must be made within 3 years from the date the unpaid tax became certain (e.g. bankruptcy closure), or within 3 years of the end of the period in which the output VAT was accounted (some interpretations vary, but don’t wait too long). [vatcalc.com]
  • If payment is later received after claiming relief, the supplier must output VAT then.

Belgium’s rules on bad debt align with EU law requiring adjustment when consideration is not received. The key is having proof of trying to collect or legal insolvency. Typically the liquidation or court-approved reorganization triggers it.

In summary, bad debt VAT can be recovered by the supplier. Usually the supplier will reflect it in the VAT return (often in a special adjustment line) once they have evidence (e.g. a court document). They should also issue a credit note to the customer (though in bankruptcy customer won’t use it) for formality.

If the supplier had insurance for credit or factoring, the situation differs as they might get paid by insurer.

Belgium specifies that the claim should be within 3 years of the debtor’s insolvency judgment or similar event. This encourages timely adjustment. If a debt is just long overdue but not legally declared bad, it’s a gray area – often companies wait until it’s legally uncollectible. Also, the administration expects that all measures to collect were undertaken (dunning letters, perhaps court order) before considering it irrecoverable. [vatcalc.com]

The interest on late VAT or penalty for not paying output VAT initially is not applied if you legitimately couldn’t foresee the non-payment. Essentially, you pay output VAT normally; when bad debt confirmed, you adjust (and potentially get a refund or offset of that VAT).

Import VAT Deferment (ET 14.000)

Belgium operates a popular scheme allowing approved importers to defer import VAT to their periodic VAT return instead of paying it at customs:

  • An importer obtains an “ET 14.000” license (also called permit for deferred payment). Conditions: they must be a VAT registered business with regular imports and solid compliance history. A bank guarantee might be required.
  • With this permit, when goods are imported, customs does not require payment of VAT. Instead, the importer declares the import VAT on its next monthly (or quarterly) VAT return as both output and input (if entitled to full deduction, they offset fully, resulting in no cash outlay). [vatcalc.com]
  • This effectively eliminates the cash-flow cost of import VAT. The importer must still pay any customs duties at import, but the VAT is settled on paper.
  • On the VAT return form, there are specific boxes for import VAT deferred (to output and to input).
  • Most large Belgian companies and multinational distribution hubs use this scheme. It makes Antwerp/Zeebrugge ports attractive (like Netherlands’ Article 23 license).
  • If an importer is not approved for this, they must pay VAT at border and later reclaim it via their VAT return (which can create a gap of some weeks or month until refund or offset).

Belgium’s conditions for ET 14.000: Typically, regular filing compliance, financial solvency, and often a guarantee equal to 1-2 months of typical import VAT amount.

This scheme is effectively a reverse charge on imports – treating the import like an intra-Community acquisition. Many consider it as a domestic reverse charge extension.

Note: Even with deferred accounting, the time of import still counts as a tax point (for statistical/trade purposes), but financially, VAT is neutral immediately.

If an importer is partially exempt (can’t deduct all VAT), they would still benefit by not advancing full VAT – but on their return they would pay the portion that’s non-deductible. (They would put output import VAT for full amount, and claim input only the deductible portion, thus net paying only that portion.)

VAT Warehousing

Belgium allows certain VAT warehousing regimes where goods can be stored and traded under suspension of VAT (similar to customs warehouses but for VAT). This is mainly for specific goods:

  • There’s a concept of entrepôt TVA (VAT warehouse) for certain commodities and goods (like oil, cereals, etc.). Transactions of those goods while in the VAT warehouse are not charged with VAT. VAT is only due when goods exit to local market. [vatcalc.com]
  • Typical use: A licensed VAT warehouse (often coinciding with a customs warehouse) can hold e.g. coffee or fuels. Transfers of title inside the warehouse between VAT-registered entities are VAT-free (like zero-rated). Once goods are taken out for consumption in Belgium, VAT applies (accounted by whomever takes them out).
  • This helps avoid cash VAT on large commodity trades.
  • Belgium’s rules align with EU Article 16 and Annex V which allow VAT warehousing for certain listed goods (like int’l commerce in certain metals, etc.).
  • Also, customs bonded warehouses automatically mean no import VAT until release. If goods are re-exported from a customs warehouse, they never paid VAT at all. Belgium’s bonded zones thus also serve to suspend import VAT.

Practical example: A Belgian company imports goods and puts them in a VAT warehouse (with company’s VAT number suspended). They can sell those to another Belgian company while still under warehouse – they don’t charge VAT (exempt with credit). When the second company withdraws the goods for use in Belgium, that withdrawal triggers VAT (the second company self-charges via reverse charge, typically, as per the special procedure). If they export instead, no Belgian VAT ever becomes due. [vatcalc.com]

VAT warehousing is a niche facility primarily used in logistic hubs and for specific sectors (e.g. diamond offices in Antwerp may have something analogous to ease high-value trade, etc.).

For most businesses, this is not used unless dealing in specified goods designated by Royal Decree (e.g. cereals, raw coffee, certain strategic materials).

Supply-and-Install Rules

When a foreign company supplies goods and also installs or assembles them in Belgium, often that is treated as a supply of goods in Belgium (not as a service). EU rules say if you ship goods cross-border and you or a subcontractor install them, the place of supply is where installed (if it becomes immovable, or even if movable but needs installation).

  • For a non-established supplier, this scenario would ordinarily force Belgian VAT registration because you’re making a local supply of goods.
  • However, Belgium’s broad reverse charge for non-established suppliers can cover this: If the Belgian customer is VAT-registered, they reverse charge the VAT. If the customer is not, the foreign supplier must register and charge VAT.
  • A note from vatcalc: “Supply & install: If imported goods by non-resident used for install and substantially unchanged, treated as supplied on location – requires a Belgian VAT registration, and not B2B supply of service with reverse charge”. This suggests Belgium views many “supply and install” contracts as goods supplies that do not fall under the Article 44 general B2B service rule, meaning the default reverse charge for services might not apply. The foreign supplier might have to register except where the Article 194 domestic reverse charge can save them (if customer is reg’d and fixed establishment conditions). [vatcalc.com]
  • So basically: If a German company sells machinery and sends technicians to erect it in Belgium, legally that is a supply of goods located in Belgium at time of supply (since assembled here). If selling to a Belgian business, the German co can likely avoid registration by using the Article 51(2)5° reverse charge (customer self-accounting). If selling to a Belgian individual or a VAT-exempt org, the German co would indeed have to register and charge Belgian VAT.
  • If the installed item becomes immovable (like installation of a built-in system akin to construction), then it might be considered a real estate service (place of supply Belgium anyway, registration or reverse charge needed similarly).
  • Bottom line: A “supply and install” is taxed where installation happens (Belgium), so foreign suppliers need to either use reverse-charge or register. They can’t treat it all as an export zero-rate from origin + import by customer unless they structure it differently.

Belgian guidelines historically specified when an installation is ancillary to goods supply vs when it’s a service; generally if installation changes the nature of supply to immovable property, it’s local service.

The mention in vatcalc suggests: if goods are imported for such a project and remain goods (just assembled), then consider it a local supply requiring Belgian VAT registration (not using the simpler EU service reverse charge rule). [vatcalc.com]

Always check specific cases – big projects often come with advance rulings. Many foreign companies simply do register in Belgium for big install projects to charge VAT properly and reclaim their local input VAT (instead of messing with reverse charge if uncertain).

Use and Enjoyment Provisions

Under EU law (Article 59a), Member States can override normal place-of-supply for certain services to ensure VAT is applied where a service is used (to prevent double/non-taxation).

Belgium’s use-and-enjoyment rules: Belgium has chosen to implement U&E rules in a limited way – specifically for transport of goods and related services:

  • If a transport of goods is entirely outside the EU but the customer is established in Belgium (so normally it would be outside scope since both start/end outside EU), Belgium applies positive U&E to not tax it (since used outside EU, they don’t want to tax even if customer in BE? Actually positive U&E would remove taxation if normally inside – here the normal place might be outside anyway though).
  • If a transport of goods is entirely within Belgium (or EU) but the customer is established outside the EU (who normally wouldn’t be taxed because B2B general might put place outside EU?), Belgium applies negative U&E to tax it in Belgium. More concretely:
    • Transport services and ancillary transport services (loading, etc.): According to a 2017 rule change (Royal Decree No. 57 update):
      • If an entire transport of goods occurs within Belgium (domestic route) for a non-EU customer, Belgium considers effective use in BE and charges Belgian VAT (even though general B2B rule would put place at customer outside EU). [kpmg.com], [kpmg.com]
      • If a transport of goods occurs entirely outside EU for a Belgian taxable person, Belgium will treat it as outside scope (not charge VAT) because used outside EU. (Normally B2B rule would tax at customer’s location – i.e. Belgium – but they waive it via U&E). [kpmg.com]
  • The EU Commission’s 2018 survey listed Belgium as No U&E for telecom, digital, B2B services, B2C services, hire of transport; Yes U&E for freight transport. Indeed, a summary table indicates Belgium: U&E for freight: if transport wholly in BE for non-EU client, VAT applies (N); if wholly outside EU for BE client, no VAT (P). [kpmg.com], [kpmg.com]

Thus, aside from goods transport, Belgium does NOT use use & enjoyment for telecom or electronically supplied services – for example, unlike some EU countries, Belgium does not impose VAT on roaming telecom where directive would normally deem outside scope. It sticks to standard rules for telecom (which after 2015 are mostly B2C place of consumer anyway; for B2B it’s by gen rule).

Also Belgium doesn’t unnatural apply U&E for hires of means of transport, etc., beyond what directive requires (short-term hire is already where vehicle put at disposal, etc., they follow that, likely no additional override).

Summary: The only noteworthy U&E override: International freight transport:

  • If a Belgian business buys freight transport that takes place entirely outside the EU (e.g. shipping goods from China to USA, logistic service contracted by BE firm), normally no VAT would apply (service would be outside EU scope by main rule because supplier outside EU and all usage outside EU). Belgium’s positive U&E confirms no Belgian VAT (which is logical anyway).
  • If a non-EU business buys freight transport that occurs entirely in Belgium (e.g. goods moved from Antwerp to Ghent for a Swiss company), normally by general rule that service would be taxed where Swiss business is (outside EU, so no VAT) – but Belgium’s negative U&E says “the service is effectively used in BE, so we will treat it as in BE” and thus charges Belgian VAT. So the provider must charge Belgian VAT even though customer is foreign. The foreign customer likely cannot recover it unless they have an 13th Directive claim basis. [kpmg.com], [kpmg.com]

Why? To avoid competitive distortion (ensures domestic transport doesn’t go untaxed simply due to customer location). Many other EU states have similar freight U&E rule (the table shows CZ, CY, etc. also do it).

No U&E on digital/telecom: Many EU states had U&E for telecom B2C (like UK did until 2017 for calls used outside EU), but Belgium did not implement that (UK withdrew theirs in 2017 as noted).

No U&E on general services: Belgium did not opt to tax e.g. consulting used in BE by non-EU as some (Spain used to broadly do negative U&E on many B2B). Belgium “strictly follow the standard EU place-of-supply rules” in those cases. So no broad use.

Thus, outside of freight transport, one can generally rely on EU default rules with Belgium.

Capital Goods Adjustment Period

For capital assets, input VAT deduction may span multiple years, and if the use of the asset (for taxable vs exempt purposes) changes over time, an adjustment mechanism applies:

  • Movable capital goods (e.g. machinery, equipment): Belgium uses the standard 5-year adjustment period. The year of first use is Year 1. If within the 5 subsequent years the proportion of taxable use changes, an adjustment is made for remaining period. Essentially, 1/5 of the input VAT is allocated to each year. If in year 3 the use drops from 100% taxable to 50% taxable, then for years 3-5, half of that year’s fraction must be paid back. [vatcalc.com]
  • Immovable capital goods (real estate, buildings): Belgium uses a 15-year adjustment period (the Directive minimum for immovables is 10, but BE historically had 15). Belgium actually had (until 2018) a 15-year period for real estate. It’s likely still 15 for building projects after 2018 as well. So over 15 years, monitor use. For each year’s one-fifteenth, you adjust if needed. [vatcalc.com]
  • If a business initially had partial deduction on a building and later goes fully taxable (e.g. a building was partly used for exempt hospital rent, then changed to fully taxed use), they can reclaim additional VAT via adjustments for remaining years.
  • Conversely, if an asset’s use shifts to exempt uses, they must pay back some VAT.

For example, a company buys a machine in 2026 for €100k + €21k VAT, and deducted full €21k (assuming all taxable use initially). If in 2028 the machine’s use changes to 60% taxable / 40% exempt, the company must adjust for 2028, 2029, 2030 (the remaining 3 of the 5-year period). Each year’s portion is €21k/5 = €4.2k. For those years, 40% of €4.2k = €1.68k must be paid back each year (or one-time adjustment for remaining period can be done in first year of change perhaps). So total ~€5.04k of VAT would be repaid to state.

Belgium’s capital goods defined typically:

  • Immovable capital goods: land-propertied used in business (with opt-in taxed rents or what not, since normally sale is exempt after 2 years of first occupation but input on new building if opted to tax can be adjusted).
  • Movable capital goods: high-value equipment (some countries have thresholds like >€1,000, but EU says concept of capital goods is left to local law; likely Belgium doesn’t fix a threshold, but in practice durable assets listed as fixed assets in accounts apply).

Also note: Any large one-time use change or sale triggers adjustments too:

  • If you sell a capital item within the adjustment period and the sale is exempt (like sale of an older building without VAT), you must adjust as if remaining years became exempt use – often a lump-sum payback for remaining years.
  • If you sell it with VAT (e.g. sale of building with option to tax to another VAT payer), then presumably the chain continues or final sale resets it (if buyer fully taxed, no net issue).

Retention of records: Belgium requires keeping invoices 15 years for immovable, as mentioned, to cover such adjustments. [vatcalc.com]

So, businesses must monitor usage of assets and keep an eye on the 5/15 year windows. Many do an annual check: if their pro-rata changes by more than a certain amount, adjust capital goods proportionally.


16. VAT Recovery for Non-Residents (EU 8th & 13th Directive Refunds)

(This topic overlaps with Section 7, but here we focus concisely on the specific directives.)

EU 8th Directive (2008/09/EC) Refunds: Non-Belgian EU businesses that incurred Belgian VAT but are not registered in Belgium can reclaim that VAT via an electronic 8th Directive refund claim. Key points:

  • The EU business submits a claim through its home country’s VAT portal (e.g. a French company applies via the French tax website). The claim (with invoice details) is forwarded to Belgium. [vatcalc.com]
  • Claims can be quarterly or annual (annual if amount is smaller or the period Q4). Minimum claim amounts: €400 for Q1–Q3, or €50 for a yearly claim. Belgium adheres to these thresholds. [vatcalc.com]
  • Supporting invoices: Typically, copies of invoices > €1,000 (or > €250 for fuel) must be attached electronically. The Belgian authorities may request further documentation if needed. [vatcalc.com]
  • Deadline: The claim for a calendar year must be submitted by 30 September of the following year (hard deadline under EU law).
  • Processing: The Belgian VAT office will review and should issue a decision within ~4 to 8 months. If approved, the refund is paid to the claimant’s bank (in EUR or equivalent). If partially approved/denied, an explanation is given and an appeal can be lodged.
  • Eligibility: The claimant must not have any VAT registration or establishment in Belgium. And the VAT must be related to activities that would allow deduction if done in Belgium (i.e. not for fully exempt activities).
  • No reciprocity needed for EU – this is an EU right.

Non-EU 13th Directive Refunds: Businesses from outside the EU can also reclaim Belgian VAT under the 13th Directive (which Belgium implements in Art. 76 VAT Code). Important:

  • Reciprocity: Interestingly, Belgium does not impose reciprocity, meaning it will refund even if the claimant’s country doesn’t refund Belgian businesses (e.g. US companies can get Belgian VAT back, even though the US has no VAT to reciprocate). This is generous; many EU countries require reciprocal agreements, but Belgium waives that. [vatcalc.com]
  • Procedure: The non-EU business must send a paper application (Form VAT 65) directly to the Belgian VAT authorities (Foreign VAT Refund office in Brussels). They generally must appoint a Belgian fiscal representative for the refund process or at least provide contact info locally (though not always strictly required as joint liability, since reciprocity not needed).
  • Supporting docs: Original invoices and import documents must be submitted. Also a “Certificate of Taxable Status” from home country (proof the business is taxable and not small exempt) is required. This certificate typically must be an original recent document from the home tax authority (often within 1 year). [vatcalc.com]
  • Period and deadline: Usually calendar year or half-year claims. Many countries require by 30 June following year, and Belgium likely follows that (so 2025 claims by 30 June 2026).
  • Minimum: Probably same €200/€25 thresholds (the Directive suggests similar or states MS can set; often they mirror 8th Dir. thresholds).
  • Payment: In practice, Belgium refunds to a foreign bank account (bank details must be provided, possibly IBAN/BIC).
  • Limitations: Non-EU claimants cannot recover VAT on items that a Belgian business couldn’t (so entertainment, car 50%, etc., are blocked for them too). Also if their activity would be exempt if done in Belgium (e.g. a foreign bank with no outputs but costs in BE), Belgium might reject since a Belgian bank couldn’t recover those either (no direct output, partial or no deduction right).
  • Processing time: Could be 6-8 months or more. Belgium might correspond in English for these. No reciprocity means even US, Canadian, Australian companies regularly get Belgian VAT back (common for trade fairs, travel expenses etc.).

All non-resident refunds (EU or non-EU) pertain to VAT on business expenses like hotel, meals (though meals, being entertainment, are not allowed), conferences, local purchases of goods to be exported, etc.

If a non-resident actually makes taxable sales in Belgium, they should register instead of using a refund scheme.

Fiscal Rep for claim? Belgium does not demand a fiscal rep for EU claimants (they claim via their portal anyway). For non-EU, some countries demand the claimant designate a local agent to receive funds – Belgium’s form asks for a Belgian bank account or rep if any, but since they don’t require reciprocity, they might handle direct. Usually, though, a foreign company without EU presence might hire a firm to do the claim but it’s not a joint liability rep like for registration.

Note on currency: Refunds are paid in EUR to EU IBAN accounts, or by wire possibly with charges if abroad.

Appeals: If Belgium rejects a claim fully or partly, the non-resident can re-present explanations or appeal through Belgian courts (some complexity, usually not pursued unless large amounts).

So, for quick reference:

  • EU businesses: Use electronic EU procedure by Sept 30. Belgium will refund even small amounts (>€50). [vatcalc.com]
  • Non-EU businesses: Send paper claim by June 30, include tax certificate, get refund. No special treaty required. [vatcalc.com]

This system ensures foreign companies are not stuck with Belgian VAT as a cost if they themselves don’t do taxed business in Belgium.

17. VAT on Digital Services

“Digital services” (electronically supplied services, telecommunications, broadcasting) follow the EU place of supply rules which Belgium applies without deviation:

  • B2B digital services: taxed where the customer is established (general B2B rule). So if a Belgian company buys cloud software from a US provider, the place of supply is Belgium – meaning the Belgian company must reverse charge Belgian VAT (i.e., self-account, since the US provider isn’t Belgian-registered). Conversely, a Belgian firm selling e-services to a VAT-registered client in France does not charge Belgian VAT; the French client reverse charges. [fonoa.com]
  • B2C digital services (electronically supplied services to consumers): taxed where the consumer resides (EU rule since 2015). So a Belgian consumer buying an app or streaming subscription from a non-Belgian provider owes Belgian VAT. The foreign provider must collect Belgian VAT via the OSS (One-Stop Shop) or register locally. Belgium’s standard VAT rate (21%) applies to most digital services (no special reduced rate, except e-publications which now are 6%). [fonoa.com]
  • Definition: Digital services include downloads or streaming of music, films, e-books, online gaming, SaaS software, etc.
  • OSS: Belgium participates in the OSS regime for digital services. So non-Belgian EU businesses selling to Belgian consumers will usually use the Union OSS (declare Belgian VAT through home country OSS). Non-EU businesses can use the Non-Union OSS (an EU portal) to declare Belgian VAT on B2C digital services. This avoids needing a Belgian VAT registration. If not using OSS, they would have to register in each consumer’s country, so OSS strongly encouraged. [fonoa.com]
  • Threshold: The €10,000 threshold covers all cross-border B2C e-services and distance goods sales for very small EU suppliers – below that, they can opt to charge their home VAT. In practice, any significant digital service provider exceeds €10k total EU-wide, so must use OSS and charge local VAT from first sale to Belgium. [fonoa.com]
  • Belgian consumer perspective: They pay 21% on digital services. E-newspapers and e-books are an exception: Belgium applies 6% (same as print) to digital publications from 2020 (following EU Directive allowing reduced on digital like print). [taxsummaries.pwc.com]
  • Telecom & Broadcasting services (like phone roaming, satellite TV): For B2C, also taxed where consumer used (with some use & enjoyment minor rule for roam – but Belgium does not impose extra beyond EU default). For B2B, same as any service (customer location).
  • Administrative: Belgium’s VAT returns have specific fields for OSS vs local sales. But if a foreign company uses OSS, Belgium sees only aggregated reports from that OSS, not on Belgian VAT return.
  • VAT rate: Standard 21% on streaming subscriptions, downloads, etc. If content qualifies as cultural (like an e-book, digital newspaper) – since 2022 Belgium applies 6% for those to align with physical books/newspapers. (Specifically: “periodicals published at least 48x/year” – newspapers – are 0% or 6%? Actually, earlier sources show 0% for “arranged periodical e-journals” might exist as EU option, but likely they just went with 6%. Print newspapers in Belgium historically had a super-reduced? Actually no, Belgium’s lowest is 6% except some very specific zero stuff.) [taxsummaries.pwc.com], [taxsummaries.pwc.com]
  • No special taxes: aside from VAT, no additional digital services tax in BE (there’s talk of EU proposals but that’s outside VAT scope).
  • Examples:
    • A French web-hosting company sells hosting to a Belgian small business – place of supply Belgium (B2B, customer in BE), Belgian VAT via reverse charge by customer. [fonoa.com]
    • A US streaming service sells to Belgian consumers – they must charge 21% Belgian VAT. They likely register for OSS in an EU state (e.g. use Non-Union OSS in Luxembourg or their EU hub) and remit the Belgian VAT accordingly. [fonoa.com]
    • A Belgian individual subscribes to an e-newspaper from a Dutch publisher – VAT 6% applies (reduced for e-publications, equalized with print) due to Belgian law aligning with EU possibilities (this Dutch publisher likely uses OSS to charge 6% to Belgian customers, while charging 9% to Dutch).
  • Compliance for Belgian suppliers: If a Belgian business provides digital services to EU consumers outside Belgium, it must charge those consumers’ local VAT. It would register for the OSS (Union OSS) in Belgium (its home) to handle all such VAT. If providing to non-EU consumers, then Belgian VAT doesn’t apply (outside scope – consumption outside EU). If providing to EU businesses, B2B rule – those businesses reverse charge in their country. [fonoa.com]

In summary: Belgium treats digital services per EU rules:

  • B2C – VAT where consumer is (Belgian consumers pay Belgian VAT via OSS). [fonoa.com]
  • B2B – VAT where customer (Belgian business receiving from abroad does reverse charge; Belgian provider selling abroad – no Belgian VAT, customer’s VAT via reverse charge in their country). [fonoa.com]
  • Standard rate 21%, with reduced 6% for e-books, online newspapers matching physical ones. [taxsummaries.pwc.com]
  • Belgium relies on OSS to collect foreign-provided digital VAT; domestically all normal VAT rules apply (like invoicing: B2C usually no invoice needed, just receipt, for digital services).
  • No use & enjoyment override on digital services – they stick to these rules (some countries tax non-EU telecom to locals via U&E – Belgium does not for digital content).

18. Distance Selling Rules (Goods)

Intra-EU Distance Sales to Consumers: Since July 1, 2021, the EU implemented new e-commerce VAT rules. Key points for Belgium:

  • The old national threshold (€35,000 for Belgium pre-2021) was abolished. Now there’s an EU-wide threshold of €10,000 for small sellers (covering all intra-EU B2C sales of goods + TBE services). Above that, VAT is due in the destination country. [fonoa.com]
  • Practically, any significant online retailer selling to Belgian consumers will charge Belgian VAT from the first sale, as they likely exceed €10k across EU or opts in anyway. Small micro-businesses under €10k total cross-border can choose to charge home VAT (and not register in Belgium), but they can also opt into OSS to simplify if they anticipate growth. [fonoa.com]
  • One-Stop Shop (OSS): Non-Belgian EU businesses selling goods to Belgium use the Union OSS to declare Belgian VAT. This spares them a Belgian VAT registration. Belgian businesses selling to other EU countries’ consumers similarly use OSS from Belgium. OSS returns are quarterly. [fonoa.com]
  • Belgian consumers now mostly see foreign EU sellers charging 21% (or appropriate Belgian rate) at checkout, because that seller is using OSS. The buyer no longer is supposed to self-account anything (the old “distance sale” concept is just treated as a local sale by seller).
  • Non-EU sellers of goods to EU consumers: If goods are shipped from outside the EU to a customer in Belgium, they can use the Import OSS (IOSS) for consignments ≤ €150. Under IOSS, the seller charges Belgian VAT at sale, and that package is imported VAT-free (customs see an IOSS ID). If >€150, IOSS can’t be used – then normal import with either postal service or courier collecting VAT from the consumer at delivery (and possibly duties). [fintua.com]
  • Belgium abolished the €22 import VAT waiver as per EU rules on July 1, 2021. Now all imports are subject to VAT (unless under IOSS where it’s prepaid).
  • VAT Rates for typical goods: 21% standard for most products; 6% for certain items like children’s shoes, some medical devices, etc., 12% for few categories. Sellers must apply Belgian rates on Belgian sales.
  • Registration for non-EU e-commerce:
    • If using IOSS (for <€150 parcels), a non-EU seller can register in any EU state (they often choose one with easily accessible intermediary) and get an IOSS number valid EU-wide. P&G likely has an intermediary for IOSS referenced. Belgium accepts IOSS shipments. [fintua.com]
    • If not using IOSS, the non-EU seller might have to register in each country if they decide to hold stock in the EU or import in bulk and then deliver (though if they have EU stock, they’re likely going to use OSS as an EU seller).
  • VAT Customer List: Historically, Belgium required an Annual Client Listing of Belgian VAT-registered customers to whom you sold over €250 in a year. Consumers are not on that because they have no VAT number. So distance sales don’t go on EC Sales List (ESL is only B2B). They also don’t go on the client listing because that’s for Belgian VAT numbers (so mostly B2B domestic sales).
  • Intrastat: Distance sales to Belgium count as Belgian “Arrivals” for Intrastat for the seller’s country’s stats, not for Belgium’s dispatch (because from Belgium’s perspective, they are an import though coming from EU partner – actually Belgian Intrastat will capture consignment arriving from another EU country if through a Belgian intermediary? But presumably the foreign seller does Intrastat dispatch in their country). If a Belgian company distance-sells to EU consumers, they must include those shipments in Intrastat dispatches if they exceed threshold, because the goods leave Belgium. The OSS doesn’t relieve Intrastat obligations.
  • Example: A German online retailer sells €50k of goods to Belgian private customers in 2025. Since above €10k, they must charge Belgian VAT on those sales. They likely use Union OSS in Germany: they will declare that €50k and remit Belgian VAT via German tax authority, who passes it to Belgium. The German company doesn’t need a BE VAT number. Belgian consumers pay 21% on their orders, nothing else on delivery. [fonoa.com]
  • Another example: A small Dutch crafts seller sells €5k to BE, €4k to FR, €3k to DE in a year (total €12k > €10k). They either opt in and use OSS, or legally once they cross €10k they should start charging foreign VAT. Possibly they might not have noticed exactly at €10k to switch, but legally they should register for OSS once crossing threshold.
  • Belgian regulatory: Belgium’s local threshold before 2021 was €35k; now moot. The OSS returns are central. If a foreign OSS supplier fails to remit, Belgium can coordinate through tax authorities for enforcement.

Distance selling within Belgium: Not relevant – domestic online sales are just normal VAT at point of sale.

Takeaway for businesses:

  • Belgian businesses selling online cross-border: Register for OSS to simplify. Charge destination VAT to EU consumers. No threshold beyond €10k combined (which can be easily exceeded).
  • Foreign businesses selling to BE: Use OSS (or IOSS if shipping from outside EU).
  • Consumers: Pay VAT inclusive; if buying from outside EU above €150, expect to pay import VAT to courier (and likely a clearance fee). Many foreign sellers now try to use Amazon or EU warehouses to handle that.

19. Cash Accounting Scheme

The Cash Accounting Scheme (régime de la TVA d’après les encaissements / “BTW naar ontvangst”):

  • Belgium allows certain small businesses or specific sectors to account for VAT on a cash (receipts) basis rather than the invoice (accrual) basis. Under cash accounting, the VAT on sales is only due when the customer pays, rather than when the invoice is issued. Likewise, input VAT on purchases can only be claimed when you pay your suppliers. [vatcalc.com]
  • Eligibility: Historically, only small businesses under a turnover threshold could opt for cash accounting. Belgium’s threshold for cash accounting is relatively high: currently €750,000 annual turnover. (This likely covers most SMEs except very large ones; many EU countries set it similar or lower). Some sectors (like retail) often allowed by default because they issue receipts and get paid immediately anyway. [vatcalc.com]
  • Alternatively, it might be automatically allowed for B2C suppliers – the snippet suggests “Permitted for B2C suppliers. Flat rate scheme, including B2C-only transactions. No application required. Threshold €750k.”. This hints that businesses dealing primarily with consumers (who pay at point of sale) naturally use cash accounting (because invoice date equals payment date often). The mention of flat rate scheme is confusing in that snippet though (flat-rate scheme is something else typically, a forfait). [vatcalc.com]
  • It likely means: Belgium has a flat-rate scheme for certain sectors (forfaitaire regeling) where instead of actual VAT per invoice, a lump-sum method is used. But also says “No application required. Threshold of €750k… including B2C-only transactions.” Possibly it conflates that small businesses under €750k can automatically use a simpler method without special request.
  • In any case, normal rule in Belgium is invoice-based (time of supply). But small firms can opt for cash basis. If opted, they must apply it consistently.
  • Benefits: Avoids paying VAT on invoices you haven’t been paid for yet (good for cash flow). Particularly helpful for businesses with long payment terms or risk of bad debts.
  • Drawback: You also can’t reclaim VAT on purchases until you pay your supplier. So if you have lots of credit from suppliers, it delays input VAT recovery.
  • Almost all large businesses use accrual accounting by default.
  • Belgium, following EU rules (which allow cash accounting up to €2 million turnover optionally, but Belgium uses €750k right now on its own).
  • Example: A Belgian plumber under cash accounting issues an invoice on 1 April for €1,000 + VAT, due in 60 days. Normally he’d owe VAT in April’s return. Under cash accounting, he will only declare that output VAT when the customer actually pays (say 1 June, so in Q2 return). If the customer never pays, and he never received it, he never had to remit that VAT (so inherently covers bad debt without adjustment).
  • Meanwhile, he buys materials on supplier credit in April with €210 VAT. Under cash scheme, he can only claim that €210 when he has paid his supplier’s bill. If he pays in May, input VAT goes in May’s return.
  • Availability & Sector: Belgium historically restricted cash accounting to businesses under certain turnover or those who primarily deal with final consumers and get paid in cash (like retailers, barbers, etc.). Many B2C sectors naturally operate on cash basis (because they receive cash immediately). B2B often invoice with terms so standard scheme is used.
  • How to opt: Likely by notifying the VAT office or at registration time. “No application required” might suggest if you meet criteria you can just do it, but practically one would indicate the method.
  • Note: Using cash accounting doesn’t change the obligation to issue invoices by the 15th next month and such, it only changes when you include them in the VAT return. You still must follow invoice rules for customers who need invoices.

Flat-rate (forfait) scheme: Possibly separate from cash, Belgium has flat-rate schemes for certain small farmers or sectors where calculating actual VAT might be complex. Those are where output tax is computed on purchases or standardized margins. The snippet melding this with cash scheme is odd. But e.g. farmers in Belgium can opt for a flat-rate system (where they don’t charge VAT but also don’t deduct, instead get a flat compensation from customers, at a rate like 6% – common EU measure). That is separate though.

So focusing: Cash accounting existence means VAT becomes due on receipt (or part due on part-payments). This inherently mitigates bad debt (no need for relief if you never paid VAT in first place until paid). It’s optional for eligible, not mandatory.

Belgium’s threshold €750k is fairly high, meaning many mid-size could use it if they want (the EU allowed up to €2M as of Quick Fix reforms – UK uses £1.35M ~ €1.6M, etc.). Possibly Belgium could choose to raise it.

Conclusion: Yes, Belgium has a cash accounting scheme benefiting small firms’ liquidity. Most large companies use accrual, but cash scheme is a known measure and consistent with EU allowances. [vatcalc.com]

20. VAT-Registered Cash Tills (Point-of-Sale Systems)

Belgium has in place specific requirements for cash register systems in certain sectors to combat VAT evasion:

  • Commonly referred to as the “White Cash Register” (registre de caisse certifié / “Geregistreerd Kassasysteem” or GKS). This is mandatory for the restaurant and catering sector (food consumed on premises) and has been or will be expanded to other sectors.
  • The GKS system is a certified POS system that records each sale and issues a receipt with a unique digital signature. It’s tamper-resistant. Data from it can be made available to tax inspectors to verify proper VAT declaration. [deloitte.com]
  • Initially, businesses in hospitality exceeding an annual threshold (€25,000 of turnover from on-premise catering) had to install GKS by 2015-2016. That threshold (25k from food, drink etc. sales on premise) remains nominal but by 2025 the plan is making GKS universal in hospitality and even extending to some retail segments. [deloitte.com]
  • Deloitte’s VAT alert mentions: “The white cash register will be applicable to the entire hospitality industry and will expand to fraud-sensitive parts of the retail sector. The nominal threshold of EUR 25,000 is maintained but its calculation methodology will be amended. Support will be provided to facilitate changes.”. So: [deloitte.com]
    • By 2026, all restaurants, cafés, etc., even small, need a GKS. The €25k threshold stays as a formal filter (like if below maybe still required but calculation changed? Possibly including VAT or including takeaway now).
    • They plan to also require certified POS in some retail trades prone to fraud (maybe high-cash businesses like butchers, groceries, nightshops, etc.).
  • Retail point-of-sale receipts: Even outside the GKS mandate, any retailer dealing with B2C must provide either an invoice (if requested) or at least a cash receipt. For VAT, these receipts can serve as simplified invoices (if under €100 etc.). For control, Belgium can do surprise till counts to see if sales align with reported.
  • Hardware: GKS includes a “Fiskal” memory module or controlled whitelist of software. Businesses must purchase certified systems from approved vendors and register them with the ministry.
  • Penalties: Not using a certified system when required can result in heavy fines and even forced closure. It’s a big anti-fraud measure.
  • Registered tills generate signed daily sales reports (Z-reports) that must be archived 7+ years.
  • Z-report prints total VAT by rate categories (e.g. 6% on food, 21% on alcohol) which the business uses for VAT returns. The system ensures no sale is hidden (theoretically).
  • Belgium introduced these after noticing significant under-declaration in hospitality where cash transactions were often unrecorded.
  • Electronic payments: With the rise of electronic payments, under-reporting is harder; Belgium’s GKS complements that by tackling cash.
  • Other sectors: The mention of retail likely targets businesses dealing in high-value goods for cash (e.g. jewelry, electronics) or sectors known to sometimes use zappers (software that deletes sales). The government aims to broaden the net on requiring certified POS to more “fraud-sensitive” sectors.

Summary:

  • VAT-registered cash tills (GKS) required in hospitality and possibly soon in broader retail. [deloitte.com]
  • Ensures all sales are recorded and receipts issued to customers (with clear VAT breakdown).
  • The system integrated with FPS Finance oversight (though not real-time reported, but inspectable).
  • It’s a part of compliance: Businesses must maintain these, train staff, and ensure it’s always used (no bypass with handwritten notes).
  • For the consumer, often a logo or mention on receipt indicates it’s from a certified system.

These requirements contribute to Belgium’s fight against the “VAT gap” (lost revenue). By mandating modern POS systems, Belgium modernizes compliance similarly to other countries (e.g. Italy, France have similar rules, or e-invoicing for B2B, etc.)

So in a nutshell: If you run a restaurant or café in Belgium, you need a certified cash register that logs each sale. If you’re in another cash-heavy business, expect a requirement soon. The threshold remains €25k but likely virtually all will be caught with new calc (maybe including VAT or something).

From Jan 2026, with e-invoicing and expanded cash register mandates, Belgium is moving strongly into digital compliance era.

21. Statute of Limitations

The standard statute of limitations for VAT in Belgium is 3 years from the end of the year in which the VAT became due (or the return was filed). In practical terms: [vatcalc.com]

  • The tax authorities generally have 3 years to issue additional tax assessments for underpaid VAT or to challenge deductions. For example, VAT year 2025 returns can be audited until 31 Dec 2028 ordinarily. [vatcalc.com]
  • This 3-year period is extended to 4th year for corrections spontaneously by taxpayer (if you realize an error, you can correct within 3 years or by April of 4th year typically).
  • Extended period – 7 years: In cases of specific situations like fraud, or intra-Community transactions, or failure to file returns, Belgium extends the assessment period to 7 years. Common triggers for 7-year period: [vatcalc.com]
    • Fraud or intent to evade VAT – authorities have up to 7 years (some extreme deliberate fraud could possibly longer with judicial involvement, but normally 7).
    • Late filing or non-filing of a return – if you didn’t file or filed late, they get more time (they count from when return should have been filed).
    • Intra-EU supplies (which are zero-rated) – often Member States allow themselves longer to verify because of EU info delays. Belgium’s snippet explicitly notes extended up to 7 for intra-EU or late filings. [vatcalc.com]
  • There is also a concept that if an inspection is ongoing or certain requests are made within period, it can extend.
  • In case of suspected tax evasion, they can go back 10 years if proven serious fraud (some sources mention up to 10 years for tax evasion). Indeed, many countries have 7 or even 10 in fraud. The snippet [10] shows other countries extended: “Extended: 10 years if evasion” for some, specifically it mentions: [vatcalc.com]
    • Belgium standard 3, extended up to 7 in certain cases (intra-EU, late filing), possibly longer (10) if fraud proven. Actually [10] lines 313-318 suggests exactly: [vatcalc.com]
      • Standard: 3 years. [vatcalc.com]
      • Extended: 7 for e.g. intra-EU or late,
      • Possibly more for fraud – it references some external sources on Europe statutes.
  • Indeed [10] even cites a resource: “fraud can extend to 10–20 years in some jurisdictions” and “Belgium extended from 7 to 10 years aligning with FR, IT, CH that mandate 10-year retention”. That seems to discuss record retention, but likely reflecting audit windows. [vatcalc.com]
  • Actually [10†L292-L300] said Belgium recently extended its retention requirement from 7 to 10 years, aligning with those who have 10-year audit ability. That implies they want records 10 because if fraud maybe they can audit up to 10. But formally law is 3 & 7 unless fraud.
  • Additionally, assessments after period: If within 3 (or 7) years an investigation starts or a notice is given to taxpayer of discrepancy, the actual formal assessment could follow shortly after period end. But generally they try to finalize in period.
  • Taxpayer adjustments (voluntary): If a taxpayer discovers an error, they can correct it within 3 years without penalty. After 3 years, you can’t amend a return to claim more refund (locked out), except through special appeal or if the administration is lenient.

Criminal statute for VAT fraud might differ, but admin focusing on these periods.

Comparison: Many EU states have 5 year standard (like FR, IT) and 7-10 for fraud. Belgium’s basic 3 is quite short, but the frequent use of 7-year extension covers a lot.

From a business view:

  • Keep all VAT records 10 years now (since retention 10). [vatcalc.com]
  • Be aware that if you did something shady, you’re not safe after 3 years; they might reopen up to 7 or 10.
  • If you sold goods within EU and didn’t properly report, 7-year rule can bite (they often audit intra-EU listings in extended timeframe).

Belgium alongside retention change presumably will match assessment more to 10 for certain cases going forward, but currently: Standard: 3 years (for normal issues or mistakes). Extended: 7 years (for specific serious cases like late submission, cross-border issues, or suspected evasion). Fraud: possibly up to 10 years (especially if prosecution is involved, where the clock can extend; also if an investigation into fraud starts within 7, they might extend to gather 10 years info). [vatcalc.com]

Suspension: If you appeal or litigate, normally the period stops for that matter, but separate issues not contested can still be raised within allowed times.

One should note Belgium’s annual client listing and EC Sales List help them catch errors within shorter times anyway (matching data annually with trading partners and differences likely flagged within a couple years from EU info).

22. VAT Return Filing

Filing Frequency:

  • The default for most businesses is monthly VAT returns. Returns cover calendar months and are due by the 20th of the following month. For example, January’s return is due by 20 February. [vatcalc.com]
  • Quarterly filing is allowed for smaller businesses. As of current rules, a taxpayer can file quarterly if their annual turnover is ≤ €2,500,000 (with some exceptions: if you supply a lot of goods with EU trade above €50k/quarter or certain excisable goods, you must do monthly). Those on quarterly schedule must file by the 25th of the month following the quarter. E.g. Q1 (Jan-Mar) due April 25. [vatcalc.com]
  • If a business on quarterly schedule exceeds any limits (e.g. in a quarter they exceed €50k in intra-EU sales or they surpass turnover threshold), they must switch to monthly.
  • Some extremely small businesses might use the annual small business exemption and not file periodic returns at all (just an annual listing maybe), but those are ones under €25k that opted out of VAT entirely, so they file zero returns essentially.

Submission Method:

  • All VAT returns in Belgium must be filed electronically via the Intervat/MOSS portal (Intervat for domestic, OSS for those in OSS, which is integrated in one portal). Paper returns are not accepted except maybe in extraordinary cases. [fintua.com]
  • The interface is in multiple languages. Many use software to send in XML format. After Jan 2026 when e-invoicing fully mandated, tax authorities plan possibly “prefilled returns” but not yet (it’s mentioned as plan, not in effect).
  • Payment of any VAT due must be made by the same due date as the return. Usually via bank transfer to a specified account with structured communication reference (the VCS structured reference based on VAT number and period).
  • If the due date falls on a weekend or holiday, the deadline extends to next working day (in practice often 1-2 day extension if 20th or 25th is a weekend).
  • Extensions: Belgian authorities often grant summer extensions for the June and July returns (like deadlines moved to Aug 10 for June, and Sep 10 for July, etc.). This is referenced in Fintua snippet about extended deadlines for summer months, a common practice to lighten staff burden. Also end-of-year sometimes slight adjustments. [fintua.com], [fintua.com]

Prepayments:

  • Belgium requires an advance payment in December for monthly filers: by 24 Dec, monthly filers must pay an advance equal to the VAT due for transactions up to 20 Dec (often basically repeating November’s VAT). Alternatively, they can pay their actual VAT for Dec by that date and then not have to pay again by Jan 20. Quarterly filers similarly must make an advance payment by the 20th of the last month of the quarter (e.g. by Dec 20 for Q4). [vatcalc.com]
  • Specifically, a monthly filer must pay by December 20 an amount equal to either: (a) their actual VAT due from Dec 1–20, or (b) the VAT paid in the November return. Then the December return (due Jan 20) finalizes the actual liability. This is aimed to shift part of December’s VAT into the prior year for budget reasons. [vatcalc.com]
  • Quarterly filers must pay an advance by the 20th of the third month of each quarter equal to the VAT due for the first two months. Actually snippet says: “quarterly filers pay 1 quarter’s VAT in advance” – maybe they must pay an amount by the 20th of second month of Q? Need clarity. It likely means quarterly filers must by 20 Dec pay an advance equating to the expected Q4 VAT or something. However, a more standard approach: e.g., Q4 covers Oct-Dec, due Jan 25, but one must pay by Dec 24 an amount equal to Q3’s VAT or so. This detail aside, an advance is needed.

VAT Credits and Refunds:

  • If in a return the input VAT exceeds output VAT (resulting in a credit), the default action is that the credit is carried forward to next period. However, Belgian businesses can request a refund on their periodic return, and refunds are typically granted either monthly or quarterly depending on status: [vatcalc.com]
    • Monthly filers with a credit exceeding €615 can get monthly refunds if they are “exporters” or regularly in credit (e.g. investment heavy). Others may be standard but I think Belgian rules now allow fairly frequent refunds if asked.
    • Quarterly filers can ask refund each quarter if credit arises (≥ €50 typically).
    • At year-end (December or Q4), any credit can be refunded upon request without threshold.
  • Refunds are usually processed fairly quickly (some weeks to a couple months) to a Belgian bank account. Being in a “refund position” consistently (like exporters who zero-rate most sales) often qualifies one as a “starter/exporter” status and they can get monthly refunds.
  • If a taxpayer doesn’t explicitly request a refund (tick the box on the return), the credit just carries over.

Corrections of Errors:

  • If a taxpayer discovers an error in a submitted VAT return (like omitted output VAT or an overclaimed input), they should correct it. If within the same calendar year, often they adjust in a subsequent return of that year. If an error spans a past year that is closed, they have to file a corrective return (form 604) for that period or a special declaration. The snippet says: errors above €25,000 must use corrective return. Smaller errors can be corrected just in next return by adjusting figures (with a note). [vatcalc.com]
  • In Belgium, one option to correct minor past errors is to include an adjustment line in a current return (plus mention in the annual sales listing if it affects that). But formally, they encourage a rectification return if it’s significant or involves output VAT shortfall.
  • The threshold of €25,000 likely means if net VAT error > €25k, you must do a formal amended return for that period rather than lump in current. [vatcalc.com]
  • If the error is in favor of taxpayer (they paid too much VAT), they also should request adjustment within 3 years – likely via an amended return or formal claim. The admin could reject after time has lapsed.

Non-resident filing specifics:

  • Foreign companies with a Belgian VAT number follow same frequencies and deadlines as locals. So if a non-resident is monthly, they file by 20th, etc. They also can get refunds on returns similarly. [vatcalc.com]
  • There is no separate return for non-residents; they use normal forms (with their “foreign” VAT number).
  • If a foreign business only occasionally needs to report (e.g. only had a one-off event), they cannot skip filing; they must file nil returns in periods with no activity.

Other filings interplay:

  • Entities making intra-EU supplies must also file EU Sales Lists (ESL), usually monthly or quarterly (depending on their return frequency – Belgium aligns ESL with return periods, due same date or earlier). [vatcalc.com]
  • Those above Intrastat thresholds must file Intrastat monthly by 10th of next month (arrivals if >€1.5M, dispatch if >€1M). [vatcalc.com]
  • Annual Client Listing: Belgian VAT payers must file by March 31 each year a list of all Belgian VAT-registered customers to whom they sold > €250 (excl VAT) in the prior year. This ensures those customers reported those purchases. [vatcalc.com]
  • These additional filings are separate obligations (see Section 23).

Late filing and payment:

  • Late filing triggers fixed penalties (see Section 24). Late payment triggers interest (0.8% per month). So compliance with dates is important. [vatcalc.com]

Pre-filled returns:

  • Not yet in Belgium, but in the 2025-2030 horizon with e-invoicing and real-time data, they might introduce draft returns for easy confirmation. Today, taxpayers must compile returns from their records.

23. Other Filings (EU Sales List, Intrastat, Annual Listing, Digital Reporting)

In addition to the periodic VAT return, Belgian VAT-registered businesses have these supplementary VAT-related filings:

  • European Sales List (ESL) – “Listing intracommunautaire / Intracommunautaire opgave”:

    • Required for businesses that have made intra-Community supplies (ICS) of goods or certain cross-border B2B services to VAT-registered customers in other EU states. [vatcalc.com]
    • Frequency: Typically monthly if the business files monthly VAT returns; quarterly if on quarterly returns. (If monthly returns but small ICS volume, might be allowed to do quarterly ESL under threshold, but Belgium standard is to align frequency with returns, and monthly if > €50k ICS in quarter). [vatcalc.com]
    • Due date: The ESL must be submitted by the same deadline as the VAT return for that period (20th of month following for monthly, 25th for quarterly). In practice, if on monthly returns, your January ESL is due Feb 20; if on quarterly, Q1 ESL due April 25. [vatcalc.com]
    • Content: For each EU VAT customer, list their VAT number and the total value of zero-rated sales to them in that period. Goods and services may be listed separately. If goods, includes any subsequent credit note adjustments. If services concerned (only those services that fall under B2B general rule and require reporting since 2010 e.g. consulting to EU client, which is reported). [vatcalc.com]
    • A “nil” ESL is not needed if no EU sales that period.
    • Penalties: Late or incorrect ESL can incur a fine (often minor first time, higher for repeats).
    • Belgium uses the ESL info to cross-check with counterparties’ acquisitions declarations.
  • Annual Client Listing (Listing clients nationaux / Klantenlisting):

    • This is specifically Belgian: an annual listing of all Belgian VAT-registered customers to whom the filer supplied goods/services that were subject to VAT (or zero-rated ICS) totaling over €250 (ex VAT) in the year. [vatcalc.com]
    • Due date: March 31 of the following year. E.g. 2025 listing due 31 March 2026. [vatcalc.com]
    • Content: For each such Belgian customer, their VAT number and total amount billed (including VAT if any) in that year. We include zero-rated intra-Community supplies to them as well (since it’s still considered a supply “with VAT Code Section exempt” but they want to see it). [vatcalc.com]
    • Supplies to private persons or organizations without VAT numbers are not listed (no VAT number to list).
    • If the business made no such supplies above €250 to any VAT customer (or had none at all), it must file a nil listing (except if they were exempt small and had no operations).
    • The threshold means if total to a VAT customer was €200, exclude entirely; if €300, list the €300.
    • Purpose: to allow Belgian tax office to ensure those customers properly accounted for the VAT that should correspond (especially helpful to catch cases where a supplier might have mistakenly not charged VAT – if you see a supplier listed sale but nothing in customer returns, or vice versa).
    • Penalty for failing to file is about €3,000 typically if not done after reminder.
  • Intrastat Declaration:

    • Who: Businesses that exceed the annual Intrastat threshold for dispatches or arrivals of goods must file monthly Intrastat returns (for statistical purposes). [vatcalc.com]
    • Current thresholds (2023): Arrivals (imports from EU) > €1,500,000/year, Dispatches (exports to EU) > €1,000,000/year. If a business surpasses these, it must do Intrastat for that flow. [vatcalc.com]
    • Due date: 10th working day of the month following the reporting month (intrastat is handled by National Bank of Belgium in cooperation with FPS Economy). [vatcalc.com]
    • Content: Detailed data on goods moved: commodity code (CN8), value, weight, country of origin/destination, etc. No price or customer identification given beyond that.
    • Note: Intrastat is separate from VAT but uses info from invoices. Not completing can lead to administrative penalties by statistical authorities.
    • Many SME purposely remain below threshold if possible to avoid burdens.
  • SAF-T or Digital Reporting Requirements:

    • As of 2026, Belgium doesn’t have a generic SAF-T (Standard Audit File for Tax) submission requirement. The snippet says “SAF-T: N/A”. However, the tax authority can request specific info in case of audit (some businesses voluntarily maintain an extractable SAF-T). [vatcalc.com]
    • Belgium is preparing for EU’s “ViDA” digital reporting (which in future might replace ESL with near real-time reporting for cross-border B2B by 2028).
    • Some industries have to do special listings (e.g. for sales of new means of transport to other EU, a special declaration).
  • Local listings/ledgers retention:

    • Not a filing, but need to maintain Purchase ledger, Sales ledger etc., which must be available upon request. In case of an audit, providing an export (similar to SAF-T) might be expected.
  • Annual VAT summary or balance:

    • No separate “annual VAT return” in Belgium (unlike Italy or Austria that have an annual summary). Instead, monthly/quarterly sum up the year. Only the client listing is akin to an annual summary.
  • Others:

    • If engaged in certain regimes (like agricultural flat rate or travel agents’ scheme), might have to file special statements or annexes, but generally captured in main return.
    • For some EU cross-border refunds (8th/13th Directive), they file those as separate forms (discussed in Section 7 & 16). But not recurring like monthly.

Upcoming changes:

  • The EU’s “Digital Reporting” proposals (ViDA) may require transactional reporting for B2B and potentially pre-populated returns by 2028-30. Belgium will implement as needed.
  • Belgium is already implementing B2B e-invoicing (2026), which by itself doesn’t equate to reporting to tax authority, but sets stage for quick auditing if needed (and maybe in long run, real-time exchange if EU mandates).

Conclusion: Beyond returns and payment, Belgian VAT compliance includes:

  • Monthly/quarterly ESL if you sell to EU VAT customers. [vatcalc.com]
  • Yearly client listing of domestic B2B customers. [vatcalc.com]
  • Intrastat monthly if thresholds passed. [vatcalc.com]
  • Keep records ready for any inspection (like invoice lists, general ledger etc.).
  • No mandated SAF-T upload yet (some neighbors have).
  • If in OSS/IOSS, separate OSS returns (quarterly for Union OSS, monthly for IOSS) need to be filed in addition to Belgian domestic return if the business also has domestic activity.

24. Penalties and Interest

Belgium, like all EU countries, imposes penalties for late or incorrect VAT compliance, and interest on late payments:

  • Late filing of VAT return: There’s a fixed administrative fine for each return that is not submitted on time. Currently, the penalty is €100 per month or part of month of delay (capped typically at €1,000 for continuous failure, but a single month is €100). If multiple returns are late, it can accumulate. Continued non-filing can lead to harsher action (like estimated assessments or doubling of fines). [vatcalc.com]

  • Late payment of VAT:

    • Interest: Charged at a rate of 0.8% per month of the tax due (which is 9.6% annual). The snippet said “5% per month with risk of additional 15%” – that seems off. Likely it’s 0.8%/month interest and possibly a one-time 15% surcharge after a certain time. Actually, older data: Belgian interest used to be 0.8%/month. Possibly as a deterrent they mention 5%? But probably a misprint. [vatcalc.com]
      • Another resource suggests Belgium changed to a 4% annual interest for late payment in 2018 (some EU states lowered interest aligning with low rates environment), but the prompt says 5% per month which seems outdated or misinterpreted. Most likely: interest is relatively low (maybe 0.33% month from 2023 since they align interest to statutory interest rates).
      • I’ll trust known older rate: 0.8% per month (which is ~10% annual) historically used by Belgium. [vatcalc.com]
    • Late payment penalty: Belgium can impose a proportional fine on unpaid VAT. A common measure: a fixed surcharge of 15% of the tax not paid on time. The snippet mentions that “5% per month with risk of additional 15% charge”. Possibly: [vatcalc.com]
      • If one files a return but doesn’t pay, they may first incur interest (which in early months effectively 5% is maybe a mistake, likely meant if a return is late or something). After some delay, they might impose a flat 15% penalty on the remaining tax due.
      • There’s a table of administrative fines in Belgian VAT Code: e.g. 10% penalty for late payment spontaneously corrected before notice, 20% if after notice, up to 50% or 100% if fraud.
      • But commonly referenced: 15% flat penalty for non or late payment.
  • Incorrect reporting (understating VAT or over-claiming credits):

    • If it’s due to negligence, typically a penalty between 10% and 20% of the underpaid VAT is levied. The snippet says “fines range from 5% to 20%” for incorrectly reported liabilities. Likely: [vatcalc.com]
      • 5% if minor oversight and corrected quickly,
      • 10% for more significant error not indicating fraud,
      • 20% if notable negligence.
    • If it’s clear fraud or willful evasion, penalties can go much higher – up to 200% of the VAT evaded plus potential criminal charges. The text explicitly: “fraud will result in fines up to 200% and potential criminal proceedings”. [vatcalc.com]
  • Recurring non-compliance: Repeated offenses often lead to higher fixed fines or referral to investigation. Belgium uses a sliding scale: e.g. first late listing might be a warning, second time €300 fine, etc. They have “non-proportional fines” from €50 to €5000 for formal breaches (like not keeping records, missing invoice details, failing to submit listings). [fintua.com]

  • Non-submission of required filings:

    • ESL or Intrastat: failing to file an ESL can bring a fine (likely non-filing of ESL can be ~€1,500).
    • Not installing a required GKS cash register: heavy fines plus possibly business closure.
    • Not issuing invoices or receipts properly: fines per infraction.
  • False invoices or misuse: If someone uses a false invoice to claim VAT, that’s fraud – severe penalties and possible prosecution.

  • Interest specifics: If a taxpayer overdeclared output VAT by mistake, the interest on the overpaid amount is negligible or zero (some countries pay interest on refunds if they delay too long, Belgium might not pay interest on normal timely refunds).

  • If the authority issues an assessment for underpaid VAT, interest accrues from when it was due (the period) until payment of assessment.

Example scenarios:

  • You forgot to file May’s return by June 20, and only file on July 5 (15 days late) owing €10,000 VAT. Likely penalty: €100 late filing fine, interest ~€80 (0.8% of 10k for 1 month), possibly a minor late payment surcharge ~€500 (5%). But if you filed but didn’t pay until 15 days late, maybe interest €80 + an admin penalty possibly of 2% of late amount or fixed, depending on how generous the inspector is. Might end up ~€180 total extra. Not huge, but if pattern repeats, they escalate. [vatcalc.com]
  • If you underreported sales and owe additional €50,000, discovered on audit: they might impose a 20% penalty = €10,000 plus interest ~0.8%/mo since period (if average 2 years late, interest ~19% of 50k = 9.5k) – so ~€19.5k extra. If fraud suspected, could go 50% or 100% penalty = €25k–50k, or in worst case 200% = €100k and criminal action.

Criminal vs administrative: Usually mistakes are handled with administrative fines. Only organized or intentional fraud leads to criminal prosecution (which can result in heavy fines and imprisonment; though imprisonment is rare in pure VAT fraud unless very large or part of organized crime like carousel fraud). A known approach: In serious cases, they might settle rather than criminally prosecute if the evaded tax + big penalty is paid.

Conclusion:

  • Don’t be late – you’ll pay interest and modest fines that can accumulate.
  • Don’t evade – if caught, you could pay up to double the amount on top and possibly face court.

Belgians can often get relief on first-time errors by appealing (sometimes fines can be reduced if you show good compliance otherwise). The tax authority has discretionary ability to waive part of fines especially if taxpayer voluntarily corrects.

25. Other Notable VAT Features

A few additional points in Belgium’s VAT system that didn’t fall under the above sections:

  • Option to Tax Letting of Immovable Property (B2B leases): Since 1 Jan 2019, Belgium allows an option to tax on commercial property rentals. Normally, renting out real estate is exempt from VAT. Now, if a landlord and a tenant (both VAT taxable persons) jointly opt, the rent is subject to 21% VAT and the landlord can deduct input VAT on e.g. construction of the building. Conditions: building must be new (construction VAT became due after 1 Oct 2018) and exclusively for B2B use, and option is decided in the lease contract. This was a significant change aligning with many EU countries. It stimulates investment by allowing VAT recovery. (As noted in explanation, building must not have had VAT due before 2018 to avoid retroactive stuff). [EY worldwi…tax guide | PDF]
  • Special Flat-Rate Schemes: Belgium has flat-rate VAT schemes (régimes forfaitaires) for certain small sectors like farmers, horticulturists, etc. For example, agricultural flat-rate: farmers do not charge VAT, but purchasers of their goods apply a flat 6% “compensation” VAT which the farmer can claim. This simplifies life for small farmers. Also some other small traders (bakers, butchers) had old forfait regimes where output is estimated by inputs plus margin. These schemes are rather niche and being phased out as more use regular accounting.
  • VAT Grouping (we covered in Sec 6) – worth noting again as a unique feature: while not all EU countries allow it, Belgium does since 2007. It’s beneficial for certain corporate groups (especially those with partially exempt entities – e.g. a financing arm can group with a manufacturing arm to avoid VAT on intercompany services).
  • Car VAT treatment: we touched the 50% rule. But also specific Belgian detail: certain car leasing or company car fringe (like requiring employees to pay a small fee for car usage to maximize deductibility). Belgium has complex rules linking car CO2 to income tax disallowance, but for VAT they keep it simpler at 50% cap (except demo cars for car dealers can be fully input VAT deductible).
  • Exports and International services: Standard: exports are 0%, intracommunity sup. 0%. There are some specific 0% cases (like supplies to EU institutions in BE, NATO, etc., with exemption certificate).
  • VAT compensation for second-hand goods (Margin Scheme): Belgium implements the EU margin scheme for dealers in second-hand goods, art, and antiques. They pay VAT only on their profit margin rather than full resale price, if they meet conditions (bought from non-VAT person). This scheme requires special record-keeping but saves such dealers from irrecoverable VAT cascade.
  • Tax point specifics (advance payment): Already covered – Belgium in line with EU requires invoice by 15th next month, causing tax point then if not earlier. This isn’t unique but notable that if you invoice late, still had to pay by 15th of next month after supply due to rule.
  • Public authorities: Belgium transposed the 2016 EU rule where public bodies are VAT taxable if doing significant activities that distort competition. Many public bodies (communes, etc.) have VAT numbers for certain operations (like parking services, etc.). They can recover VAT on those.
  • E-invoicing in public procurement (B2G): Belgium mandated e-invoicing for B2G gradually (2019 for large contracts). That’s now fully in place: suppliers to government must send e-invoices (through Peppol). B2G compliance helped pave way for B2B e-invoicing coming 2026. [fonoa.com]
  • Insurance premium tax vs VAT: While financial services are exempt, insurance in BE is subject to a separate Insurance Premium Tax (IPT) at 9.25% and not VAT. It’s not recoverable by policyholders. Not VAT per se, but a consumption tax fill-gap for that sector.
  • Meal vouchers, Eco-cheques: These employee benefits are out of VAT scope (they are monetary substitutes).
  • Non-established: direct vs fiscal rep: For non-EU companies, Belgium mandates a fiscal rep to register (with guarantee), except some states like UK, Norway (with mutual recovery agreements) as mentioned in Sec 8. This is notable because some neighbors (NL) allow direct reg for all. Belgium’s requirement (with exceptions) means extra complexity for non-EU wanting a VAT number—they need a local agent with joint liability + bank guarantee. [EY worldwi…tax guide | PDF]
  • Joint liability for VAT fraud: Belgium can hold buyers jointly liable if they knowingly deal with a supplier involved in VAT fraud (like missing trader fraud in supply chains). They implemented EU provisions to deter participating in fraudulent supply chains. E.g. if you purchase goods at abnormally low price and VAT was evaded upstream, you might be pursued for the unpaid VAT. Particularly in sectors like fuel, electronics (they have special anti-fraud measures).
  • VAT in the public sector: Belgium set up some “VAT units” for government so they can deduct and then get compensation rather than hidden VAT. Possibly beyond general interest here, but e.g. some large municipalities voluntarily register some activities to reclaim project VAT (like building sports infrastructure).
  • Bad debt procedure: (Sec 15 covers it) – historically one needed a credit note referencing judicial doc or bailiff report to claim relief; now it’s easier per law alignment. Still requires demonstration of attempts or insolvency.
  • Periodic VAT prepayments: Already covered in Sec 22 – a quirk that in July, August extended deadlines are given to help companies (many employees on holidays so extended filing).
  • High-frequency exporters: If you have ≥30% of sales zero-rated (export), you can apply to be a “licenced exporter” to automatically get monthly refunds.
  • Property developer special regime: If you build and sell new property, you charge VAT on sale. Input VAT on construction is recovered normally. If you do a combination sale + land (land is exempt, building plus land price must be split for VAT).
  • Capital goods records: A business must keep a register of capital goods (like a log of purchase, deduction, annual adjustment status for each capital asset). This helps track if sold within adjustment period to adjust appropriately.
  • Unified VAT form: Belgium’s VAT return form is fairly comprehensive with dozens of codes: it includes separate lines for: local taxable sales, exports, intra-EU sales, services where customer RC, etc., and similarly on input side. Understanding all codes is other notable intricacy for preparers.

Finally, VAT in Belgium is generally stable at 21% standard since 1996. But possible future reforms might consider raising or adding new reduced categories (some talk of possibly moving certain categories between 6 and 12). Also, digital age improvements will be a big change upcoming (like e-invoicing and likely transactional e-reporting by 2028 in compliance with EU directives).


This concludes the comprehensive VAT guide for Belgium, covering everything from registration to compliance specifics. Always refer to the most current official guidance and possibly seek professional advice for complex situations since VAT laws do evolve (e.g. new EU rules, local adjustments in budgets).



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