Important procedural VAT changes in 2025 summarized in 6 main points

Summary:

  1. The filing deadline for quarterly VAT returns and so-called ‘special VAT returns’ will be extended from the 20th to the 25th of the month after the quarter ends.
  2. A refund request via the periodical VAT return is only possible for the VAT credit resulting from the VAT return itself, and provided the VAT returns for the previous six months were submitted on time. Historic VAT credits can be marked for refund by a new ‘VAT provision account’. 
  3. Is the VAT return not submitted or submitted late? Then the taxpayer will receive a proposal for a replacement VAT return after the expiry of a three-month period following the reporting period.
  4. Does a timely filed VAT return contain a material error? Then it can only be corrected by filing a corrective VAT return, provided the deadline for that return has not yet expired. After this deadline, material errors should be rectified in the VAT return for the next reporting period. 
  5. Has the VAT administration issued a request for information? Then the taxpayer must answer it within 1 month.
  6. VAT debts can be paid by direct debit.
The Belgian legislator has decided to make sweeping changes on various 'procedural' VAT rules. These changes, orginally scheduled for 2024, will be introduced with a one-year delay from 1 January 2025. The Royal Decree introducing these changes was published on 23 October 2024. We summarize the main changes below in 6 points.  


1.    Extension of filing date for quarterly VAT returns and ‘special VAT returns'

From 1 January 2025, the filing deadline for quarterly VAT returns and so-called ‘special’ VAT returns will be extended from the 20th to the 25th of the month following the end of the quarter. This also applies to the payment of any VAT due. There are no changes to the deadline for monthly VAT returns.


2.    Reform of the VAT refund procedure

Currently, a monthly or quarterly VAT return filer can only recover a VAT credit on a quarterly basis, by requesting the refund through its VAT return. Monthly VAT return filers can apply for a monthly refund through a specific license (subject to conditions). This license will disappear and the option to apply for a monthly VAT refund will become the standard for all taxpayers filing monthly VAT returns. 

On the other hand, the way in which VAT refunds can be claimed will change dramatically. 
Currently, a VAT taxable person can request refund of a VAT credit through its periodic VAT return, refunding both the VAT credit resulting from the submitted VAT return itself and any outstanding VAT credit on the VAT current account.

As of 2025, a refund request via the periodical VAT return will only be possible for the VAT credit resulting from the submitted VAT return itself and this on condition that the VAT returns for the previous six months were submitted on time. The payment of said refund would be significantly faster. 

If there is a credit from previous VAT returns, this credit must be reclaimed through a new procedure. For this purpose, the 'VAT current account' will disappear, to be replaced by the specific 'VAT provision account'. 

Through this provision account (which will become available through MyMinfin), the VAT taxable person will be able to choose to reclaim all or a part of the amount in that account. If no refund is requested in the periodical VAT return or if the conditions for a refund are not met, that surplus will, after a review by the administration, be added to the VAT provision account. The modalities are yet to be worked out in a new royal decree.


3.    Replacement VAT return in case of late filing

As of 2025, if the VAT return is not submitted or is submitted late (after the expiry of a three-month period following the declaration period), the taxpayer will receive a proposal for a replacement VAT return.

With the replacement VAT return, the VAT administration will calculate a VAT amount due based on the highest VAT amount due in relation to the previous 12 months, with EUR 2.100 as a minimum. After receiving the replacement VAT return, the taxpayer has one month to correct the replacement VAT return and consequently submit the missing VAT return. If the replacement VAT return is not corrected in due time, the taxpayer can only correct the VAT return via an administrative appeal, or a petition to be filed with the court. In the context of this replacement VAT return, changes are also made regarding the fines imposed for late filing or payment (ranging from 5% to 15% depending on the specific infringement in terms of proportional fines). 


4.    Limitations introduced to the scope of the corrective VAT return

Under the new rules, if a VAT return, although filed on time, contains a material error, it can only be corrected by filing a correcting VAT return, provided the filing deadline for that return has not yet expired. If the return is not corrected before the filing deadline expires, the taxpayer must correct the error in the next VAT return. 


5.    Response time 1 month for request for information

The obligation is introduced to reply to a request for information issued by the VAT administration within a period of 1 month. This deadline may be extended at the request of the taxpayer in case of legitimate reasons. The deadline will only be 10 days if the rights of the treasury are at risk or in case of a refund audit.


6.    Paying VAT debts by direct debit

Following the automation of tax debt collection, it will also be possible to pay VAT debts by direct debit.


Entry into force 

These changes were to take effect on 1 January 2024. But given the required IT technical changes for the Belgian VAT administration, this date was postponed to 1 January 2025. By way of derogation, certain changes will only take effect from 1 February 2025. In any case, these rules will therefore enter in force soon, and we advise all VAT taxable persons to prepare for this. 


Contact us 

Do you have questions on these new measures? Our VAT experts are available for further advice or assistance. Please email btw-tva@bdo.be or contact one of our VAT experts directly: