July 2024 to July 2025 B2B invoicing phased rollout; Peppol likely preferred standard
Original plans to launch July 2023 likely have been delayed for a second time to start July 2024 as key decisions and planning remain. Belgium’s preferred plan is two staged: PEPPOL-based e-invoicing between taxpayers; then enhanced with Continuous Transaction Control pre-clearance with the tax authorities. Belgium is looking to synchronise with the EU VAT in the Digital Age plans for an EU standard on eInvoicing (EN 16931) system across the EU to ensure interpretability.
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An ambitious, and potentially subject to delay timetable for the introduction of mandatory B2B invoices in Belgium is being circulated to gather options. Belgium has so far not applied to the European Commission and EU Counsel for the necessary permission to mandate e-invoicing and derogate from the EU VAT Directive. It is also likely that the requirement will be restricted to resident taxpayers – foreign businesses will be excluded.
Furthermore, it is not likely that governmental live reporting will be included as with Italy SdI or much of South America.
Belgium will not impose its own e-invoicing standard as has been done in Italy and Poland. It is likely that a Peppol 4-corner framework will be adopted, already adopted for B2B in Belgium. Although it’s not yet dedecided if Peppol would be the exclusive format.
The original plan was made up of three stages, but this timetable is highly likely to slip to 2024:
- July 2024: Large taxpayers (turnover above €9 million)
- January 2025: Mid-sized taxpayers; and
- July 2025: Small taxpayers
Ministry of Finance backs e-invoicing
The Belgian Ministry of Finance had confirmed in the 2022 budget plan’s statement on rollowing out a B2B / B2C e-invoicing regime. Draft legislation will be issued in 2022 for consultation. Belgium has around €3.6billion in missing VAT revenues according to the EU’s last VAT Gap estimate.
Currently, B2B e-invoicing is permitted without the requirement to produce a paper-invoice provided both partiers confirm their agreement and there are sufficient secure controls over the issuance, receipt and storage processes.
The Belgian budget in October 2021 included a provision for the phased introduction of electronic invoicing for Business-to-Business transactions. Check VAT Calc’s global live VAT invoice transaction and e-invoice reporting tracker to see where else real-time submissions of invoices is being implemented. Register for our FREE global VAT and GST news updates.
Pre-clearance live invoice reporting to government unlikely
Belgium in unlikely to see a continuous transaction control model for e-invoicing. This would seek to replicate the success of Italy SdI, and follow plans for France delayed to 2024 and Poland for preclearance invoices. This would require a draft electronic invoice to be first submitted to basic validation and recording by the Ministry of Finance. Only at this point could the invoice be considered valid for forwarding to the customer. The tax authorities would then be able electronically check the invoice in the supplier’s and customer’s VAT return as matching. The aim is to detect errors and fraud, estimated to Belgium €3.6 billion each year based on the EU VAT Gap.
The ongoing EU VAT in the Digital Age proposals includes a strand around harmonised transaction-based reporting across the member states. This originated from the 2020 Tax Action Plan measures for a fairer and more efficient EU tax regime.