The Belgian VAT Guide for Foreign Companies

When your company wishes to enter the Belgian market or operate from Belgium on the broader European market, you will be confronted with the Belgian VAT system. Below we explain several important obligations that you must take into account as a VAT taxable person in Belgium, such as VAT identification, the filing of periodic VAT returns, the annual customer listing, bookkeeping requirements and the correct issuance of invoices.

European tax

Value Added Tax (VAT) is an indirect tax levied in Belgium on the supply of goods and services. As in the other European Member States, the Belgian VAT system is based on EU Directive 2006/112/EC. However, the concrete application and administrative obligations differ from one Member State to another. In Belgium, these rules are laid down in the Belgian VAT Code, which entered into force on 1 January 1971.

Does my company need to register for VAT?

In principle, a company must register for VAT in Belgium as soon as it becomes liable to VAT. Both Belgian and foreign companies are considered VAT taxable persons when they supply goods or provide services as defined in the Belgian VAT Code. A taxable person carries out such activities:

• on a regular basis
• independently
• with or without a profit motive
• as a principal or ancillary activity
• regardless of where the economic activity is carried out

Companies that exclusively perform VAT-exempt activities (such as certain socio-cultural activities, financial transactions or medical services, etc.) and therefore have no right to deduct VAT are in principle not required to register for VAT and may not charge VAT to their customers. However, such companies must still register for VAT when they are liable to Belgian VAT, for example as a result of intra-Community acquisitions of goods, the receipt of intra-Community services or the provision of intra-Community services.

Foreign companies (i.e. companies with their residence or registered office abroad and without a fixed establishment in Belgium) are required to register for VAT when they carry out transactions in Belgium for which they themselves are liable for Belgian VAT and for which they therefore have a right to deduct VAT. Foreign companies that can always apply the VAT reverse-charge mechanism for their outgoing transactions subject to Belgian VAT are not required to apply for a Belgian VAT number, provided this is also not required for their incoming transactions.

What obligations does a VAT taxable company have?

A VAT taxable company (with the exception of fully exempt taxable persons) must:

• register with the Belgian VAT authorities before starting its activities
• file periodic VAT returns (monthly or quarterly)
• remit the VAT charged to its customers
• submit an annual customer listing
• keep accounting records and issue invoices

VAT identification

Foreign companies have several options to register for VAT in Belgium:

• Direct VAT identification (RBI);
• VAT registration with the appointment of a liable representative (AVI). This is mandatory for companies established outside the European Union (except for the UK and Norway);
• VAT registration for occasional transactions such as fairs and exhibitions;
• One-Stop-Shop (OSS) registration.

Each system has its advantages and disadvantages. The most suitable form of VAT registration depends on the specific circumstances of your company. After obtaining a Belgian VAT number, certain obligations must be fulfilled for each VAT return period.

Periodic VAT return

As a taxable person, you are required to submit periodic VAT returns. As a rule, these returns are filed on a monthly basis. The monthly VAT return must in principle be submitted no later than the 20th day of the month following the month in which the taxable transactions took place.

In certain cases, however, you may opt to file VAT returns on a quarterly basis. The quarterly VAT return must in principle be submitted no later than the 25th day of the month following the quarter in which the transactions took place. You may opt for quarterly filing in the following cases:

• Your turnover amounts to less than €2.500.000 per year. For this purpose, your total “Belgian” annual turnover is taken into account, not only the transactions that are effectively subject to VAT;
• Your turnover amounts to less than €250.000 per year for the total of supplies of energy products, multimedia and motor vehicles.

Whether you file monthly or quarterly VAT returns also affects the filing frequency of the intra-Community listing. If you file monthly VAT returns, you are also required to submit a monthly intra-Community listing. If you file quarterly VAT returns, you may also submit the intra-Community listing on a quarterly basis, provided that the total amount of intra-Community supplies and triangular transactions during the relevant quarter does not exceed €50.000 and this threshold has not been exceeded during the previous four quarters. 

Intra-Community listing

The intra-Community listing is a control instrument that allows the tax authorities of different Member States to exchange information regarding intra-Community transactions.

As a VAT taxable person, you are required to submit an intra-Community listing, unless you have not carried out any transactions during the relevant period that must be included in the statement and no corrections need to be made to previously submitted statements.

The intra-Community listing must include three categories of transactions:

• VAT-exempt intra-Community supplies of goods;
• Supplies of goods in the Member State of arrival of the dispatch or transport of the goods, in the case of triangular transactions;
• Services that, in accordance with the general rule, take place in another Member State, where the customer is established and where that customer is liable for the VAT.

VAT refund?

Companies that carry out VAT taxable transactions in Belgium are in principle entitled to deduct the VAT they have paid on purchases and expenses from the VAT they must remit to the Belgian tax authorities. This means that only VAT on goods and services used for business purposes is deductible. VAT on private expenses or certain categories of costs (car expenses, representation expenses, hotel and restaurant expenses, etc.) cannot be deducted or can only be deducted partially.

For each VAT return period, either an amount of VAT will be payable to the Belgian tax authorities when the VAT due exceeds the deductible VAT, or a recoverable VAT balance will arise when the deductible VAT exceeds the VAT due. In the latter case, the balance can be carried forward to a subsequent period or, under certain conditions, refunded.

Whether you file VAT returns monthly or quarterly also affects VAT refunds. As a monthly filer, you may request a refund of your VAT credit up to twelve times per year. As a quarterly filer, this is limited to four times per year. The refund request must be submitted within a period of three years starting from 1 January of the year following the year in which the VAT became due.

For monthly filers, the latest refund date for the claimed VAT credit is the last day of the second month following the VAT return period (for example: the latest refund date for the VAT credit for the January period is 31 March of the current calendar year).

For quarterly filers, the latest refund date for the claimed VAT credit is the last day of the third month following the VAT return period (for example: the latest refund date for the VAT credit for the first quarter is 30 June of the current calendar year). 

Annual customer listing

The Belgian tax authorities require VAT taxable companies (subject to a few exceptions) to submit an annual customer listing. This listing contains a list of the Belgian VAT numbers of all customers to whom your company supplied goods or provided services during the previous calendar year for a total amount exceeding €250 per customer. VAT taxable customers who exclusively carry out VAT-exempt activities and foreign VAT taxable customers who are not identified for VAT in Belgium do not have to be included in the list.

The customer listing must be submitted annually no later than 31 March of the year following the calendar year to which the reported transactions relate. For each customer, the listing must include the Belgian VAT identification number, the total amount of supplies of goods and services, and the total amount of VAT due.

Accounting and invoicing

As a taxable person in Belgium, you are required to keep (limited) accounting records and to issue invoices when you supply goods or provide services. This invoicing obligation does not apply if the supplies or services are VAT-exempt and you, as the supplier or service provider, have no right to deduct VAT. There is also generally no obligation to issue invoices for supplies to private individuals for private use.

As from 1 January 2026, companies established in Belgium must exchange invoices electronically and in a structured format via the Peppol network for domestic B2B transactions. For foreign companies, this obligation only applies if they have a VAT fixed establishment for VAT in Belgium or carry out their activities through a subsidiary established in Belgium. In such cases, electronic invoices must be sent and received via the Peppol network in a structured format in accordance with Belgian legislation.

Would you like to learn more about the Belgian VAT system or apply for a Belgian VAT number?

Please contact our VAT advisors for further information.