🎧 Listen to This Article
On January 27, 2025, the Belgian VAT authorities released Circular Letter 2025/C/6, which outlines significant changes to the VAT filing and payment processes as part of the ongoing modernization initiative known as the “VAT chain.” In response to feedback from tax professionals regarding timing issues, the authorities have reinstated certain tolerances that were previously in place. An additional communication was released on January 30, 2025, addressing these adjustments.
Extension of VAT Filing and Payments
New Deadlines
The revised VAT chain extends the filing and payment due dates for quarterly VAT returns and European sales lists to the 25th day of the month following the reporting period. However, the filing and payment deadlines for monthly VAT returns remain unchanged, due by the 20th of the month following the reporting period.
Notably, the circular letter introduces a transitional period for returns with a statutory filing date before October 1, 2025. If the filing deadline lands on a Saturday, Sunday, or a public holiday, both the filing and payment dates will automatically shift to the next working day. This extension for quarterly returns will be phased out for returns due after October 1, 2025, though monthly filers will continue to enjoy this grace period.
To receive reimbursements for VAT credits resulting from returns, taxpayers must adhere to these new deadline provisions. Additionally, the extension applies to VAT returns submitted to finalize substitute VAT return procedures and requests for information. The existing “summer regime,” which permits taxpayers to file June and third quarter VAT returns by August 8 and September 10 respectively, will also be maintained for 2025 and possibly beyond, though it only affects filing dates and not payments.
Easing of Penalty Policies
Late Filing
To support compliance, the Belgian authorities have adjusted the late filing penalty policy. Declarations with a filing date before October 1, 2025 will not incur late filing penalties if submitted by the 10th day of the second month following the reporting period. However, after this date, penalties will be imposed for late submissions but can be waived upon written request for first-time infringements, provided the return is submitted by the specified deadline.
Non filing and Late Payment
The authorities clarified that infringements occurring after January 1, 2025, will be evaluated within the four-year reference period for non filing fines. For late payments, a fine will be imposed only if VAT is not paid by the 10th day of the second month following the declaration period. This does not apply if a late payment negatively impacts the Belgian Treasury or if it seems the delay was avoidable by the taxpayer. Late payment interest will be charged from the first day overdue, making timely payment crucial.
Additional Updates
Changes to VAT Accounts
As of October 1, 2025, both the current account and the special account for managing late or non-submission of VAT returns will be discontinued. Taxpayers can request full refunds of cumulative VAT credits for periodic returns submitted prior to this date by selecting the refund request box on the return. If no refund is requested, any remaining credit will automatically transfer to a provision account starting October 1, 2025.
New Bank Account for VAT Payments
A new bank account number, BE41 6792 0036 4210, will be implemented for VAT payments starting October 1, 2025. Until then, payments must be directed to existing accounts. Payments made to the old account after the transition date will be automatically transferred to the new account.
Conclusion and Implications for Taxpayers
The VAT chain changes were originally set to commence on January 1, 2024, but were postponed to allow both taxpayers and tax authorities adequate time for system adjustments. Recent developments indicate further delays, and the ongoing adjustments and varying grace periods may add to taxpayer confusion. The circular provides a detailed overview of the changes but does not resolve all questions regarding their practical implementation. Taxpayers and their service providers must closely monitor the evolving guidance to effectively adapt their internal bookkeeping processes and align with the tax authorities’ timeline.
For further details, clarification, contributions or any concerns regarding this article, please feel free to reach out to us at [email protected]. We value your feedback and are committed to providing accurate and timely information. Please note that all inquiries will be handled in accordance with our privacy policy
