14 October 2025
Phased implementation of the new Belgian VAT chain put on hold until further notice
In 2023, the Belgian legislator provided for a far-ranging reform of so-called VAT chain (i.e., the system for VAT returns, payments, audits and refunds), with a view to modernizing a series of compliance and procedural aspects.
Administrative Circular 2025/C/6 of 27 January 2025 set out guidance on the practical impact of the revised VAT chain and envisaged a phased implementation, to be fully effective by 1 October 2025.
However, the tax authorities have now postponed the further stages of implementation, and in particular the following measures:
- Introduction of a provisional account to replace the existing current account used for VAT refund purposes.
- New bank account number to be used for periodic VAT payments (BE 41 6792 0036 4210).
Accordingly, the existing current account mechanism and current bank account number (BE22 6792 0030 0047) remain (mandatorily) applicable.
Circular 2025/C/62 of 1 October 2025 also indicates that the following transitional measures will remain in force until further notice:
- a VAT refund request will result in the reimbursement of all accumulated VAT surpluses;
- quarterly VAT returns can be filed on the next business day when the 25 day of the month following quarter end falls at a weekend or on a bank holiday;
- monthly VAT returns can be filed on the next business day when the 20 day of the following month falls at a weekend or on a bank holiday; and
the fine for late filing of a VAT return will not be applied provided the filing is made at the latest on the 10 day of the second month following the return period.
Key takeaway / recommendation
While the implementation of the revised VAT chain has been halted for the time being, taxpayers should closely monitor future updates. Indeed, the transition period is expected to be ended and the transitional measures abolished, once the separate e-invoicing reform has been fully rolled out (see Mandatory structured VAT e-invoicing for B2B supplies in Belgium as of 1 January 2026 | DLA Piper).