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Tuesday, 25 June 2024

Belgium mandating B2B e-invoicing from 1 January 2026

Gert Vranckx

Gert Vranckx

Lode Van Dessel

Lode Van Dessel


Many other European and non-European countries preceded Belgium on the e-invoicing topic.  This, together with the EU Commission proposal “VAT in the Digital Age” (click here), pushed Belgium to also introduce a set of rules on mandatory B2B e-invoicing. The key drivers for this are (i) an administrative simplification (less ‘red tape’), resulting  in reducing costs and enhancing the processing of invoices and (ii) closing the VAT gap (click here), which should lead to an increase in terms of VAT collection by the VAT authorities.

From 1 January 2026 onward, Belgium introduces a B2B e-invoice obligation which concerns Belgian VAT taxable persons and foreign taxable persons performing certain transactions in Belgium.

What is an e-invoice?

For VAT purposes, an e-invoice is  defined as “an invoice that has been issued, transmitted and received in a structured electronic format which allows for its automatic and electronic processing”.

Belgium put forward the PEPPOL-BIS format as the standard to be used. But parties can freely decide to deviate from this, a long as (i) they both agree to it and (ii) at least use a format that meets the European standard on semantics and syntax EN 16-1931.

When must an e-invoice be issued?

In order to fall within scope of the B2B e-invoicing obligation, three criteria should be met simultaneously.

1.The issuer of the e-invoice must:

  • Be VAT established in Belgium.
    • A foreign entity having a VAT fixed establishment also qualifies as being VAT established in Belgium.
  • Be VAT registered in Belgium.
    • Including:
      • A VAT person benefiting from the small enterprises exemption (turnover not exceeding €25.000)
      • Agricultural enterprises benefiting from the “forfait” regime.
      • VAT groups, albeit that the member of the VAT group will have to issue the e-invoice under the sub-VAT number it was granted individually (so not using the VAT number granted to the VAT group).
    • Excluding:
      • VAT persons benefitting from a “forfait” regime other than the agricultural scheme.
      • VAT persons declared bankrupt.
      • VAT persons benefitting from a VAT exemption provided for in art. 44 Belgian VAT code. Eg.: healthcare, education, real estate services, financial services, etc. Regardless of whether such a transaction entitles them to an input VAT recovery right (eg. granting a loan to a non-EU recipient).

2. The recipient of the e-invoice

  • Being established in Belgium is not relevant. Foreign entities are also in scope.
  • Be VAT registered in Belgium and obliged to communicate this VAT number to its supplier for the transaction concerned. This means:
    • a Belgian VAT person carrying out VAT taxable transactions, excluding transactions that are VAT exempt under 44 Belgian VAT Code.
      • In addition, entities solely carrying out art. 44 Belgian VAT exempt transactions, but who are VAT registered in Belgium because they exceeded the threshold of €11.200 for intra-Community acquisitions or purchases of intra-Community services, are
    • A foreign VAT person liable for Belgian VAT for its outgoing activities, not using the One Stop Shop regime or identified in Belgium for Import One Stop Shop regime.
    • A member of a VAT Group

3.The object of the e-invoice

The supply that is invoiced by a Belgian VAT-taxable person must be located in Belgium for VAT purposes and is not exempted under art. 44 of the Belgian VAT Code. This also means that the supplier must issue invoices using their Belgian VAT number.

Supplies with application of the VAT reverse charge mechanism are included, eg. immovable work in Belgium between VAT-taxable persons.

Mixed VAT persons must only issue an e-invoices when carrying out a VAT taxable supply, not for their VAT exempt activities.

When another VAT exemptions than art. 44 Belgian VAT Code is applied, an e-invoice can also be required, except for eg.:

  • Intra-Community supplies of goods, since here the customer needs to share its non-Belgian EU VAT number in order to benefit from the VAT exemption.
  • Export supplies of goods to non-Belgian registered customers.

How can we help you?

First, you must assess whether you qualify as a subject of the e-invoicing obligation, being it as an issuer or a recipient.

Next, it is crucial to thoroughly evaluate your current invoicing set-up and assess whether you are ready to move to an e-invoicing system. This includes assessing the software used, the technological infrastructure and the capacity to generate and send electronic invoices. Is your current system flexible enough to meet these new requirements, should you perform some (minor) updates, or should you switch to a specialized e-invoicing platform?

It will be crucial to map your transactions and determine their correct VAT treatment. In this regard, we cannot overlook the human aspect. The success of the move to e-invoicing partly depends on the commitment and competence of your staff, both from a technical and VAT-perspective. Training and awareness programs for your employees are crucial for a smooth transition and to ensure that e-invoices are issued in accordance with the applicable VAT regulations.

Businesses should start preparing for this obligation as soon as possible and can leverage this obligation into an opportunity to evaluate part of, or even their entire, invoicing process.

In the assessment of your VAT position and the mapping your activities, as well as in the training of your employees, Tiberghien can assist. Do reach out to Gert Vranckx, Lode Van Dessel or another member of the VAT team should you require further support.

Gert Vranckx

Gert Vranckx

Lode Van Dessel

Lode Van Dessel

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