Services de conformité

Governments often use budgets as a platform to showcase their fiscal policies for the coming year, and Belgium has signalled its intent to refine its tax measures in the coming year.

Proposals in their budget include:

• Permanent 6% reduction for gas and electricity
• Increasing VAT on ‘unhealthy’ products and conversely reducing VAT on healthier products

Once again, countries are targeting specific community agendas, by adapting tax measures with a focus on advancing the health of individuals.

Belgium is a compliant territory for Tungsten Network and will accommodate any new VAT rates as part of our solution.

Belgium’s standard VAT registration number comprises of a ‘0’ followed by 9 digits. The VAT number in a country uniquely identifies taxpayers.  

As the current sequence of VAT numbers in Belgium is almost exhausted, the VAT number format is now in need of modification. It is expected that the number format will be exhausted within a year. 

To this effect, the Banque-Carrefour des Enterprises is proposing to issue ‘1’ prefixed numbers to the existing Belgium VAT number format. Existing VAT numbers will remain unchanged.  

This will require some action from businesses in terms of their accounting and ERP billing processes to accommodate the change.  

If implemented, the change may also require some modifications to Tungsten’s internal systems. We are closely monitoring timeframes for the expected VAT number format change, while also assessing the impact of the potential VAT number format change. Tungsten Network will implement any required changes to accommodate the new number format when required.  

The Russia / Ukraine conflict has compelled many countries to review their fiscal policies, especially in relation to electric, gas and heating – especially as Russia serves as conduit for many of these essential supplies. 

Further to Royal Decree No. 2022015061, which entered into force on 1 August 2022, the Belgium tax authorities have cited the following changes: 

• Extension of the 6% reduced VAT rate on electricity supplies under residential contracts until 31 December 2022 
• Extension of the 6% reduced VAT rate for the provision of natural gas and energy heating systems from 1st August 2022 August 1 to 31 December 2022 
• A reduced VAT rate for certain heat pump operations, specifically on hybrid setups that use energy supply.  

Considering the continued conflict and rising inflation globally, we expect many other countries to enact similar fiscal policies over the coming autumn and winter. 

2020 and 2021 saw a proliferation in the tax rates countries deployed as a direct response to the unfolding covid pandemic. 

2022 has seen countries attempt to steady their tax rates, but as part of the transition to a post-covid era, countries are still factoring in the pandemic as part of their wider fiscal agendas. 

Belgium is one such country which envisages the effects of covid extending into the winter of 2022, as it announced that goods imported to combat covid-19 will be exempt from VAT until 31 December 2022.  

Belgium has shifted the timeframes for B2B implementation in line with the following: 

• 1 July 2024: mandatory e-invoicing for businesses with an annual turnover of more than 9 million 
• 1 January 2025: mandatory e-invoicing for small and medium businesses  
• 1 July 2025: all other taxpayers 

Member States require approval from the European Union to mandate e-invoicing. This is currently pending.  

As previously stated, it is expected that Belgium will favour the PEPPOL e-invoicing model, in sharp contrast to recent mandates in Poland and Italy.  

2022 has seen multiple countries adopting fiscal measures with a distinctly ‘green’ agenda. Such initiatives demonstrate that the VAT framework is intrinsically linked to broader social programmes.  

Belgium is following the lead of its European neighbours in engineering markedly ‘green’ measures.  

To this effect, the Green Party in Belgium has put forward a proposal to remove VAT on fruits and greens, citing, among other arguments, the spiralling cost of living fuelled by inflation.  

Country VAT rates are under constant revision and review. The High Council of Finance in Belgium has indicated that it is contemplating increasing the VAT rate to 22%.

This is by no means definitive, but Tungsten Network will keep up to date with any developments and incorporate any new rates in our system.

Belgium, Netherlands, and Luxembourg representatives have convened to discuss plans to reduce the VAT gap.

Although Continuous Transaction Controls (CTC) have proven to be extremely popular in the past few years, with a means to reducing the VAT gap, the VAT gap remains high- 134 million Euros was lost in revenue the EU in 2019.

Shared borders and economic interests between the 3 countries have prompted the countries to work together to reduce this gap yet further- a key factor in the implementation of e-invoicing mandates.

A Royal Decree has been published outlining the modalities regarding the obligation for entrepreneurs in the context of public contracts and concession contracts (B2G).

Below are a few key timeframes regarding e-invoicing obligations:

• 1 October 2022: public contracts and concessions the estimated value of which is less than European threshold
• 1 April 2023: public contracts and concessions the estimated value of which is less than EUR 30 000 excluding value added tax, but less than European threshold
• 1 October 2023: all public contracts and concessions

The Official Royal Decree can be found via the following link.

B2G e-invoicing regulations are already in place for multiple regions in Belgium (Brussels, Flanders and Wallonia). B2G e-invoicing will now be extended to the suppliers of all public entities in all regions across the country. The obligations will be implemented in a phased approach, based on the size of public contracts.

The Belgian government has approved a royal draft decree to this effect. This draft law has not yet become law so the proposed dates are provisional, however, it is expected that by September 2023 the obligation will extend to all public contracts, irrespective of the value of the public contact.

It is however expected that contracts below 3000 Euros will be exempt from the obligation to use e-invoicing.