BDO Indirect Tax News

Changes to Belgium’s “VAT chain” rules that were due to take effect on 1 October 2025 have been postponed indefinitely to give taxpayers additional time to prepare for the transition and focus on the introduction of electronic invoicing starting on 1 January 2026 and give the Belgian tax administration an opportunity to conduct more thorough testing. VAT chain is the name designated by the tax authorities to the series of compliance/procedural changes to the rules.

A number of the measures to modernise the VAT chain became effective on 1 January and 1 May 2025, but the remaining measures have been put on hold, including the new VAT refund procedure, the use of the new bank account number and the new payment method via direct debit (for prior coverage, see the article in the April 2025 issue of Indirect Tax News). 

Overview of Key Changes

 The most important changes to the VAT chain rules (and their effective dates) are as follows:

• Extension of filing deadlines (implemented): The filing deadline for the periodic VAT return (as well as payment of VAT) and the intra-Community Sales Listing for quarterly taxable persons is extended to the 25th day of the month following the quarterly period.
• Abolition of the corrected/revised VAT return (implemented): Corrected/revised VAT returns may no longer be filed after the statutory filing deadline; any corrections must be included in the next VAT return.
• Response to a request for information (implemented): Taxpayers are required to respond to a request for information from the VAT administration within one month. This deadline can be extended or shortened (10 days in the case of a VAT refund audit) for legitimate reasons or if the rights of the Treasury are at risk.
• Substitute VAT return (implemented): If a periodic VAT return is not submitted within three months after the taxable period, the VAT administration will propose a substitute VAT return in which it calculates the VAT amount due based on the highest VAT amount due in the previous 12 months, with a minimum of EUR 2,100. The taxpayer has one month following receipt of the substitute return to amend it by filing a correct VAT return for the relevant period. If the substitute VAT return is not corrected/filed in time, the taxpayer’s only recourse is to file an administrative appeal or a lawsuit.
• Penalty policy on late or non-filing/payment (implemented): New and stricter proportional and non-proportional fines are imposed for late or non-filing and/or payment of VAT. Previous administrative tolerances have been eliminated.
• VAT refund procedure and current account rules: A change to the VAT refund procedure that became effective on 1 May 2025 involves the (standard) option to request a monthly VAT refund. However, the replacement of the “VAT current account” rules by a “provision account” will be postponed.
• Changes to account numbers for VAT payments: The current bank account number (BE22 6792 0030 0047) will remain in use for the payment of periodic VAT returns. The new bank account number may not be used, even after 1 October 2025, as originally planned.
• New payment method for VAT via direct debit: The plan to allow taxpayers to have their VAT payments automatically debited from their bank accounts starting on 1 January 2026 is also postponed.

BDO Insights 

Once the above measures are in effect, the VAT rules on fines and audits will become stricter and likely will be accompanied by an enhanced focus by the VAT administration, resulting in more intensive VAT audits in the event of noncompliance. The tightening of the rules for making corrections to submitted VAT returns means that previously submitted VAT returns cannot simply be amended. Affected taxpayers should use the additional time before the measures become effective to review their systems and processes and adapt them to the new compliance requirements and seek professional advice if needed.

Pascal Dauw
BDO in Belgium