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 |
Auteur(s) :
- Pieterjan Smeyers
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