New Legislation Simplifies and Optimizes the VAT Chain
As of January 1, 2025, new legislation has come into force aimed at simplifying and optimizing the VAT chain (the mechanism by which VAT is collected and deductible at each stage of the supply of goods or services to an end user).
The main goal is to streamline procedures and make them more efficient for both businesses and the tax administration. Below is a comparative table with the key measures before and after the entry into force of this new VAT legislation.
| Before the introduction of the new VAT chain | After the introduction of the new VAT chain | |
| Filing and payment deadlines | ||
| Monthly filers | Deadline: the 20th of the month following the reporting period | Deadline unchanged |
| Quarterly filers | Deadline: the 20th of the month following the reporting period | Deadline: 25th of the month after the filing period |
| Administrative tolerance | ||
| Holiday arrangement | Tolerance for the months of June and July | Tolerance abolished (transition period: summer 2025) |
| Extension of filing deadline to the next business day | Extension of the filing deadline to the next working day if the last day is a Saturday, Sunday or public holiday, for monthly and quarterly filers | Maintained for monthly filers, abolished for quarterly filers (from October 1, 2025) |
| Correction of a material error in the periodic return | Possibility to overwrite a previous return within 12 months via Intervat – replacement of a new balance in box [71] or [72] | Correction of a material error discovered after the filing deadline must be included in the next periodic VAT return. |
| Substitute VAT return | Introduction of a “substitute return” procedure by the VAT administration in case of non-filing after 3 months: the highest VAT amount from the previous 12 months or a minimum amount of EUR 2,100 will be charged. | |
| Request for information | No response deadline for a request for information | Response deadline of one month (with the possibility of extension for legitimate reasons), in certain cases limited to 10 days (e.g., during a VAT refund audit and if the rights of the treasury are at risk). |
| A new provision account | Use of the current account | Replacement of the current account with a provision account funded by non-refunded VAT credits and VAT prepayments – used by the Federal Public Service Finance to settle VAT debts. |
| Refund of VAT credit | Refund of the full balance of the current account via a request in the periodic return | From October 1, 2025, refunds are limited to the VAT credit included in the periodic VAT return (subject to timely ad hoc filing and submission of returns for the preceding 6 months, minimum amount of EUR 50, and timely notification of a bank account number via form E-604A or E-604B). |
| Penalties | – No return: 1,000 EUR per return; – Late return: 100 EUR/month up to a maximum of 1,000 EUR; – No proportional penalty for non-payment, except when a special account was opened | – No return: EUR 500 to EUR 5,000 per return – Late return: EUR 100 to EUR 500 per month – Non-payment: proportional fine of 5% to 15% |
| Ex officio assessment | Requires intervention of the Minister of Finance or their representative | May be carried out by the VAT administration itself. |
| Account numbers and payment methods | VAT account numbers for current account VAT (receipts Brussels) and outside the current account VAT, depending on the registered office of the taxpayer | New account numbers effective from October 1, 2025: Payment of VAT without enforceable title: BE41 6792 0036 4210 Payment of VAT after establishment of enforceable title: BE41 6792 0000 0054 Direct debit via bank transfer available from early 2026 |
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