Modernisation of the VAT chain: phased rollout from 2025

Extended deadline for those submitting quarterly returns

Currently, the deadline for submitting a VAT return (and paying the VAT debt) is set at the 20th of the month following the return period for both monthly and quarterly declarants.

From 1 January 2025, quarterly declarants will have an additional five days. This means that they will have to submit their VAT return and pay the resulting VAT balance by the 25th of the month following the end of the quarter. For monthly declarants, the deadline remains the 20th of the month following the return period.

New refund procedure

Currently, VAT credits can be claimed via periodic returns, whether they arise from the submitted return or are still outstanding on the current account.

For returns submitted from 1 May 2025, it will only be possible to claim a refund on the periodic return for the credit resulting from that particular return. Credits from earlier returns must be claimed through the VAT Provision Account in MyMinfin starting 1 May. With this provision account, you can:

• Request a refund for the account balance, in whole or in part;

• Eventually use the account balance to settle outstanding administrative debts.

With the introduction of the provision account, the VAT current account will be abolished from 1 May 2025.

Refunds for monthly declarants will occur at the end of the second month following the return period. This eliminates the need for separate licenses for monthly refunds or expedited refunds for new businesses.

Note: A refund request via the provision account automatically triggers a VAT audit, during which the authorities will verify the accuracy and validity of the declared VAT credit.

Substitute returns

In addition to the usual penalties for late submission of VAT returns, VAT taxable persons who fail to comply with their obligation to submit returns will also receive a proposal for a substitute return. This substitute return will be sent after the third month following the return deadline. This proposal will include an amount of VAT due equal to the highest amount due on the returns for the 12 months preceding the return period, with a minimum of €2,100. You will then have one month to file the correct return.

If no correct return is submitted within this timeframe, the substitute return becomes final. At that point, disputing the return can only be done via an administrative appeal or a petition to the court.

However, the Belgian administration retains the right to correct this declaration in the event of a VAT audit.

Legally defined response time

At present, there is no legally defined response time for VAT inquiries, other than the general principle of a 'reasonable period'. From 2025, response deadlines will be legally established, similar to those for direct taxes. You will have to respond to a request for information within one month from the 3rd working day after the request was sent. This time limit may be extended for valid reasons.

In certain cases, such as where the rights of the Treasury would be at risk or where the request is part of an audit of a VAT credit, this period is reduced to 10 days.

Option for direct debit payments

Currently, you pay VAT debts by manual bank transfer with a structured communication. This will remain the case for another year. From 2026, things will be more convenient: you will also be able to pay VAT debts by direct debit.

Correcting a submitted return

Until now, if you discovered an error in a submitted return, you had to file a corrected return. From 1 January 2025, this process will change:

• Is the error discovered before the deadline? Then you can replace the original return with a new one.

• If you discover the error after the deadline? Then you must make the correction in your next periodic return.

If you have questions about how these changes will impact your business or how to prepare for them, our tax department is here to help! Feel free to contact us using the form below.