Belgium: Updated VAT Processing Guidelines with Transitional Implementation

On 30 January 2025, the Belgian Federal Public Service Finance published guidelines to clarify the practical implementation of Circular 2025/C/6, which was released on 27 January 2025. 

These guidelines detail the updates under the “New VAT Chain” aimed at modernizing tax collection in Belgium. The key amendments, which became effective as of 1st January 2025, are outlined below: 

1. Corrective VAT Returns 

As of January 2025, corrective VAT returns can no longer be submitted after the submission deadline. 

Corrections can only be made when a material error is identified within the initial deadline for VAT returns. 

A material error includes errors such as: 

• Failure to include a correction related to an invoice already issued. 
• Incorrectly exercising the right to deduction. 
• A revision that was not carried out correctly. 
• Once the due date for VAT submission has passed, any material errors must be declared in the first return due to be filed, where the correction will be treated as a “positive” or “negative” correction. 

2. Response Time for Queries 

Taxpayers must now respond to queries from the Federal Service within 1 month after receiving the query letter. 

This response time is reduced to 10 days when: 

• The Treasury’s rights are at risk. 
• There is a refund request included in the VAT return. 

3. Substitute VAT Return Procedure 

If a VAT return is not submitted within three months after the declaration period, the Federal Service will send a proposal for a “Substitute VAT return”: 

• The proposal will generally include the highest amount of tax due from VAT returns filed over the previous 12 months. 
• If there are no returns submitted for the prior 12 months, or if the tax due is less than EUR 2,100, the proposed substitute VAT return will set the tax due at EUR 2,100. 
• The proposed Substitute VAT return will be notified by registered mail, and the taxpayer must submit the return within one month from the notification date. 
• If the VAT return is not submitted within the month, the Substitute VAT return will be considered final and can only be challenged through an administrative appeal. 

4. Fines and Penalties 

• The fee for late VAT return filing ranges from EUR 100 per month, up to a maximum of EUR 5,000. 
• The fee for the failure to submit a VAT return EUR 500 for the initial offense, increasing up to EUR 5,000 for subsequent offenses. 

Late Payments:

• 5% of VAT due if the return is filed on time but payment is delayed. 
• 10% of VAT due during the Substitute VAT return procedure. 
• 15% of VAT due for a final Substitute VAT return. 

5. VAT Provision Account System

A new VAT provision account system is being implemented, offering greater flexibility in managing VAT liability payments and refunds. 

The old VAT account system will remain available until 1 October 2025. 

6. VAT Refund Requests 

VAT refund requests can now be made exclusively through a checkbox in the VAT return. There is no longer a need for additional monthly refund authorization. 

VAT refunds can also be requested through the new VAT provision account. 

7. Payment Deadlines 

Payments must be made by the 20th calendar day for monthly taxpayers and the 25th calendar day for quarterly taxpayers, regardless of the return submission date. 

A direct debit payment option will be available starting in early 2026. 

These changes are part of the Belgian government’s broader efforts to modernize and streamline VAT collection processes, providing more flexibility and ensuring timely compliance. Taxpayers are advised to familiarize themselves with these updates to ensure compliance with the revised regulations. 

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