Phased Introduction of B2B e-invoicing in Belgium
Phased introduction of B2B invoicing in Belgium from July 2024 to July 2025; Peppol’s likely preferred standard
The original launch date of July 2023 has most been pushed back to July 2024, as critical decisions and planning remain.
To gather options, an ambitious and potentially subject to delay timetable for the implementation of required B2B invoices in Belgium is being disseminated. Belgium has not yet requested authorisation from the European Commission or the EU Counsel to require e-invoicing and deviate from the EU VAT Directive. Furthermore, It is likely that the rule will apply only to domestic taxpayers, with overseas corporations excluded.
Moreover, unlike in Italy SdI or much of South America, governmental live reporting is unlikely to be included.
Belgium will not enforce its own e-invoicing standard, as Italy and Poland have. A Peppol 4-corner framework, which has already been established for B2B in Belgium, is expected to be adopted. Although it has not yet been decided if Peppol would be the exclusive format.
The initial design called for three stages, although this deadline is expected to be pushed back to 2024:
- July 2024: Large taxpayers (annual revenue greater than €9 million)
- January 2025: Mid-sized taxpayers
- July 2025: Small taxpayers
The Ministry of Finance supports e-invoicing
The Belgian Ministry of Finance announced the implementation of a B2B / B2C e-invoicing system in the 2022 budget plan. In 2022, draft legislation will be released for public comment. According to the EU’s most recent VAT Gap assessment, Belgium is losing roughly €3.6 billion in VAT receipts.
Currently, B2B e-invoicing is permitted without the need for a paper invoice as long as both parties acknowledge their agreement and suitable safe controls are in place over the issuance, receiving, and storage processes.
In October 2021, the Belgian budget includes a provision for the stepwise implementation of electronic invoicing for business-to-business transactions. Check out VAT Calc’s global live VAT invoice transaction and e-invoice reporting tracker to see where else real-time invoice submissions are being used.
Pre-clearance Live invoice reporting to the government is doubtful in Belgium, as is a continuous transaction management approach for e-invoicing. This would strive to repeat the success of Italy SdI and would follow plans for France, which had been postponed until 2024, and Poland for preclearance invoices. This would need the submission of a draft electronic invoice to the Ministry of Finance for basic certification and recordkeeping. The invoice could only be regarded valid for forwarding to the customer at this point. The tax authorities would then be able to electronically compare the invoices in the supplier’s and customer’s VAT returns to ensure that they matched. The goal is to discover errors and fraud, which are anticipated to cost Belgium €3.6 billion per year due to the EU VAT Gap.
The ongoing EU VAT in the Digital Age plans include a strand centered on cross-membership harmonised transaction-based reporting. This stems from the 2020 Tax Action Plan policies aimed at making the EU tax system fairer and more effective.
