e-Invoicing mandates and updates: Belgium

August 2023

E-Invoicing launch delayed in Belgium due to political disagreements

Belgium’s plans to launch a PEPPOL based e-Invoicing model in July 2024 have collapsed. Parliamentary opposition parties rejected the proposal, citing a lack of confidence in the government’s revenue estimates from the proposal. The proposed e-Invoicing reforms aimed to increase tax revenue by reducing the VAT gap.

The withdrawal of the proposal means a substantial delay. Any fresh attempt to gather political agreement and revisit the reforms are impossible until after the summer elections in 2024.

Given the delay, it’s unlikely any e-Invoicing reform will come to Belgium before January 2026 at the earliest.

March 2023

Long-awaited tax reform proposal in Belgium finally announced

On 2nd March 2023, Belgian Finance Minister Vincent Van Peteghem took a significant step toward reform by launching a proposed first phase of the Belgian tax overhaul. After months of anticipation, his government formally presented the proposal it is now entering the legislative process. The goal? To solidify a reform plan by early April, followed by an official vote during the summer.

The proposed changes hold Companies face substantial implications for e-Invoicing and e-Reporting with these proposed changes. These should be phased in beginning 1st July 2024.

In response to a Parliamentary question, Van Peteghem confirmed that he intends to make the electronic issuing and receipt of invoices mandatory for a large majority of taxpayers.

The stated aim of the reform is to have a positive effect on the VAT gap, which accounted for 4.8BEuro or 14% of the expected Belgian VAT revenues as of 2020. The new obligations will decrease errors and restrict potential fraud, reducing the gap over time. The Belgian government is also preparting other measures to address this gap.

Van Peteghem recognized that the reforms proposed require an application for derogation from Articles 218 and 232 of the EU VAT Directive. He also confirmed that the Cabinet of the Ministry of Finance and the European Commission discussed this.

Technically the reform will require VAT registered Belgian taxpayers to send and receive structured electronic invoices for specific B2B transactions. The format will likely conform to the definition provided by the EU’s Vat In The Digital Age (ViDA) proposal, with PEPPOL expected to become the standard for exchanging e-Invoices.

Belgium has included e-Reporting obligations in the plans at the request of the European Commission. These will follow in a later phase. The current details are limited but the new obligations will likely fall in line with ViDA.

You can find details about the proposed Belgian tax reform, which also encompasses adjustments to VAT rates and more here.

April 2022

Mandatory B2G e-Invoicing moves forwards

Belgium’s plan to implement B2G e-Invoicing has proceeded with a Royal Decree that lays out the obligations for entrepreneurs. It also includes a timeline of implementation that will apply to all public contracts by 1st October 2023.

The official Royal Decree in Dutch is here.

March 2022

Benelux conference on VAT Gap

During a Brussles Benelux conference, Belgium, the Netherlands and Luxembourg called for co-operation to reduce the existing VAT gap in the EU. The VAT gap refers to the difference between expected VAT receipts and what the tax authorities had actually collected. Sharing good practices and knowledge should lead to more decisive and targeted action to detect fraud and ensure VAT is paid. In a region like Benelux, that is highly intertwined across borders and economically, this is especially true.

The loss of VAT revenue heavily affects public expenditure on goods and services such as schools, hospitals, transport and infrastructure. The missing funds could also address the many economic and health challenges surrounding the recovery from the COVID-19 pandemic.

Although the overall VAT gap in the EU Member States has narrowed since 2015, the EU countries all together still lost EUR 134 billion in VAT revenue in 2019. In addition to national action, the positive trend is also due to the EU making efforts to improve the situation. For example, there was a strong push towards the so-called transaction network analysis. Originally developed by the Benelux countries, 27 Member States are now able to identify cross-border fraud networks faster than before and target their investigations accordingly. According to Yuriko Backes, Luxembourg’s finance minister, the results of the automated data analysis tool (TNA) show an effectiveness in the fight against VAT fraud.

Benelux countries are convinced that with increased cooperation and knowledge sharing, they can take more targeted measures to put an end to VAT fraud.

February 2022

Update on Belgian B2B e-Invoicing mandate

Last month we mentioned the confirmation of Belgium’s plan to switch to mandatory e-Invoicing for B2B invoices.

On 10th February 2022, Mr Vincent Van Peteghem, Deputy Prime Minister and Minister of Finance in Belgium stressed the benefits of electronic invoicing for businesses as well as the state. It allows businesses to gain in productivity, he stated, by simplifying invoice processing and validation while combating tax fraud. The government is aware of the difficulties that could be faced by small businesses, which represent a large part of Belgium’s economic base. Van Peteghem indicated that Belgium is planning intensive exchanges with businesses and stakeholders to deploy the B2B electronic invoicing mandate project.

The proposed timing – mid-2023 – has raised objections from various stakeholders. The full scope of the proposed mandate remains undefined with no legislation in place, and no technical specifications published.

However, the Belgian government has confirmed that their model will be based on PEPPOL, which has an established network. This is quite a different approach to other member states, such as Italy and France, which developed their own platform/gateway. It will certainly accelerate the process. 

We will share more information as it is made available.

January 2022

Belgium announces a gradual move towards mandatory e-Invoicing

The Belgian finance minister Vincent Van Peteghem has confirmed their intent to follow current trends and implement a mandatory e-Invoicing system.

The government will announce details of timeline and technical requirements in a legislative proposal in 2022.

Ken Clark

Ken Clark is a Director of Product Marketing for OpenText Business Network based in the UK. For over 30 years Ken has been a subject-matter expert in the areas of digital transformation and automation, B2B/EDI/A2A integration, and e-Invoicing and tax compliance. Ken spent much of his career as a hands-on practitioner, consulting on customer problems and implementing business-focused solutions around global supply chain management, order-to-cash and procure-to-pay. Today Ken focuses on solutions for information exchange, B2B and A2A integration, and e-Invoicing.

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