The reform of the "VAT Chain" – (New) implementation delay

What changes (and when)?

Compliance

• Extension of return and payment deadlines for quarterly VAT declarants (and for the special return No. 629): Deadlines are extended from the 20th to the 25th day of the month following the reporting period. This applies to returns and intra-community listings that must be submitted starting January 1, 2025 (thus, for the first time, for the return related to Q4 of 2024).
  
  
• Retention or modification of administrative tolerances: The administrative tolerances regarding the filing/payment of periodic returns were initially removed. Ultimately, the tolerances have been maintained as follows:
  
  
  • The holiday rule will be maintained in 2025 (and possibly permanently). This concerns returns for June and July, as well as for Q2.
  • Until October 1, 2025: an extension of the filing and payment deadline until the first business day following a Saturday/Sunday/public holiday, both for monthly and quarterly VAT declarants.
    
    
• Corrections of material errors (e.g., undeclared invoices, unjustified VAT deductions, or incorrect revisions) in VAT returns can only be corrected until the end of the reporting period (20th or 25th day of the following month) or in the first VAT return following the discovery of the error. It will no longer be possible to submit a VAT return for an earlier period. This change applies to returns and listings submitted from January 1, 2025.
  
  
• Introduction of a substitute return: In case your periodic VAT return is not filed, a substitute return will automatically be established after three months following the reporting period. The VAT due will be based on the highest amount of VAT due in grid 71 of VAT returns from the 12 months preceding the reporting period (with a minimum of € 2.100).
  
  
• Consultation and management of the financial situation. From the second half of 2025, the "MyMinfin Account" project will be integrated into the MyMinfin platform. This tool will allow VAT taxpayers and their advisors to consult all credits and amounts owed to SPF Finance in one place. It will also offer practical features such as online payment, modifying bank account numbers, requesting payment facilities, and many other quick actions.

Payment/Refund of VAT

• Suppression of the checking VAT account and special account which were established in cases of non-filing and late filing of VAT returns, or non-payment of VAT debts. The checking VAT account will remain accessible until October 1, 2025.
  
  
• Introduction of the Provision Account that will replace the checking VAT account. This management tool will only be used for VAT credits that are not immediately requested for reimbursement. Taxpayers will be able to recover these credits via the VAT Provision Account or use them to pay future VAT debts. Until October 1, 2025, the checking VAT account will remain accessible for credit consultation. Starting in early November 2025, taxpayers will manage their credits through the Provision Account.
  
  
• Taxpayers will also be able to pay their VAT debts under the reformed VAT chain via domiciliation. Payments by domiciliation will not be available before early 2026.
  
  
• Regarding the new reimbursement procedure, taxpayers will only be able to request a refund of the VAT credit resulting from the relevant periodic return (grid 72), provided certain conditions are met (e.g., a minimum of € 50). For all periodic returns submitted before October 1, 2025, it is still possible to request a refund of the VAT credit under the checking VAT account system by simply ticking the "refund request" box.

Until October 1, 2025, it is also possible to request a refund of the credit at any time, even outside the return. If the taxpayer does not request this refund, the entire credit will be transferred to the Provision Account starting in early October 2025. From early November 2025, taxpayers will be able to request their refund at any time via MyMinfin.

• If no refund is requested or granted, the VAT credit will generally be recorded in the Provision Account, provided that the credit amount is at least €2,50 and there is no reason for withholding it. It is important to note that the VAT administration will first conduct checks on the VAT credit before recording it.
  
  
• The expedited monthly refund procedure will automatically apply to all monthly VAT declarants (and will no longer be limited to new businesses). Therefore, it will no longer be necessary to request authorization for monthly refunds. The authorization for monthly refunds will be abolished as of January 1, 2025.
  
  
• For quarterly VAT declarants, refunds of VAT credits requested via periodic VAT returns will be made no later than at the end of the third month following the relevant VAT reporting period. For monthly VAT declarants, starting January 1, 2025, this deadline will be reduced to the second month following the reporting period. However, if taxpayers request a refund of their VAT credit (minimum amount of € 50) via the Provision Account, the requested amount will be refunded within one month following this request. Note that for transferring credits to the Provision Account after filing a VAT return, a period of three months (for quarterly VAT declarants) or two months (for monthly VAT declarants) following the reporting period also applies.

Procedure

• Starting January 1, 2025, fines will be modified.In cases of non-payment or late payment, a proportional fine of 5%, 10%, or 15% will apply, depending on whether the filing deadline for the return has been respected or not. Before this modification, the fine was set at 15%, but only after a formal notice issued by the VAT administration. In cases of non-filing or late filing, progressive non-proportional fines will be imposed based on the number of previous infractions (ranging from € 500 to € 5.000 per return).

The VAT administration appears to slightly soften its initially strict stance in cases of exceptional circumstances related to late filing and/or late payment. Thus, a waiver of the fine for a (single) late filing is now included in the VAT penalty policy, subject to compliance with established conditions. In cases of late payment, payments received by the 10th day of the month following the payment deadline (20th or 25th of the month) will be considered, provided that Treasury rights are not jeopardized and that the delay is not attributable to the taxpayer themselves. However, it remains uncertain how this measure will be implemented concretely in practice.

• The account numbers for VAT payments have been changed. Two account numbers will be used:
  
  
  • An account number will be designated for regular payment of VAT due.
  • Another account number will be used as soon as the SPF Finances has an enforceable title or when a specific VAT debt needs to be paid.

The new account numbers can only be used starting October 1, 2025. Until that date, the old account numbers will remain valid. After October 1, 2025, payments made to the old account numbers will automatically be redirected to the correct new account number.

• Another important procedural change involves the introduction of a legal response deadline, which did not exist for VAT until now. This deadline is set at one month for requests for information regarding VAT unless legal reasons can be invoked. This deadline may be reduced to 10 days in cases involving refund audits or if Treasury rights are at risk.

The VAT team at Tiberghien is available to answer any (practical) questions you may have regarding the reformed VAT chain.