Belgian VAT Changes per 1 January 2025: The VAT Chain

The Belgian VAT administration is introducing new VAT rules regarding the VAT filing due dates, the VAT refund and other procedures with effect as from 1 January 2025.  

Submission and Payment Deadlines

Whereas to date, the deadline for filing periodical VAT returns (and European Sales Listings) is set at the 20th of the month, following the period to which the VAT return relates to, this deadline will be extended to the 25th of the month, but only for taxable persons, filing VAT returns on a quarterly basis. 

Monthly VAT returns (remain) due on the 20th of the month, but all existing tolerances (such as a delay until the first working day and the summer regime) are likely to be abolished as from 1 May 2025. 

In order to allow continuity, the following due dates are confirmed until 1 May 2025:

Corrective VAT Returns

It is no longer possible to submit corrective VAT returns after the filing deadline. All corrections after the filing deadline need to be reported in the next VAT return.

Substitute VAT Returns

If no VAT return is submitted within three months after the filing deadline, a proposal of a “substitute VAT return” will be provided by the authorities with an amount of VAT due, equal to the highest amount of VAT due (box 71) of the past 12 months, with of minimum of €2,100 of VAT due.
Filing a correct return within one month of the notification of the “substitute VAT return” will stop further action.

Penalties

The following changes apply with respect to the fines: 

• €100 per month for late submissions of VAT returns (with a maximum of €500).
• €500 for the non-submission of a VAT return (first infraction) up to €5.000
  (as from the fourth infraction)
•  Late or non-payment of the VAT due 
  • 5% if the amount due is reported in the VAT return
  • 10 % if the amount due is reported in a VAT return, filed late
  •  15% if the amount due results from a final substitute VAT return
    (after one month following the notification of the replacement VAT return)

VAT Refunds

As from 1 January 2025, the VAT refund requested in the periodical VAT return (by ticking the relevant box) is limited to the amount reported in box 72 of that VAT return, but this can be requested in any VAT return, without the need for a monthly refund license. 
The refund will be granted by the end of the second month (for monthly VAT returns) or the third month (for quarterly VAT returns) if: 

• There is no withholding (for other debts towards the Belgian State)
• The VAT return is submitted in due time
• The VAT returns for the prior six months have been submitted in time
• The refund exceeds €50
• A valid bank account number has been communicated.

Due Date for Replies to Requests for Information

Although the delay to reply to any request for information is in principle one month, this delay is reduced to ten days in case of a refund audit. Failure to respond in a timely manner to a request for information will suspend the payment of the ongoing VAT refund.

Provision Account

From 2025, a “VAT provision account” will replace the current “VAT account”. VAT credits for which no refund was (or could be) requested in the VAT return, will be transferred into this account on: 

• At the end of the second month following the period the VAT return is related to for monthly VAT returns;
• At the end of the third month following the period the VAT return related to for quarterly VAT returns.

Prior to these dates, the VAT credit can be used to settle existing tax debts, with the remaining credit, in principle, being transferred to the VAT provision account.

As soon as the credit is transferred into the VAT provision account, the refund can be requested via the MyMinfin platform (by the persons having a tax mandate to this account) whereby the refund will, in principle, follow at the end of the month in which the refund was requested.

Note that the entry into force of this provision account is postponed to 1 May 2025.

New VAT Payment Accounts

From 1 May 2025, the following bank account numbers must be used, depending on the nature of the payment:

• Bank account number BE41 6792 00036 4210: 
  • Payments on VAT provision account
  • VAT due (resulting from periodical (substitute) VAT returns, as well as interests and fines prior to any enforceable title)
• Bank account number BE42 6792 0000 0054:
  • For all VAT debts for which there is an enforceable title by the Tax authorities.

Direct debit

Starting from early 2026, taxpayers can choose to pay their VAT due automatically via direct debit.

Actions required!

Businesses should take proactive steps to prepare:

• Verify MyMinfin access for relevant staff.
• Verify the bank account on MyMinfin. 
• Train financial teams on MyMinfin’s new functionalities.
• Request VAT refund in related return.
• Update internal accounting processes to align with the new refund system.

If you would like to receive additional information on this matter or require VAT assistance, the RSM Belgium Tax team is at your disposal  via [email protected].