Ministry of Finance confirms July 2024 to July 2025 B2B invoicing phased rollout; Full govt and Parliament approval needed
Belgium’s Ministry of Finance has reconfirmed plans to commence mandatory B2B e-invoicing from July 2024. As well as e-invoicing, this will include near-live e-reporting to replace the annual customer listing report. The proposals are yet to be fully agreed by the government and submitted to Parliament.
Belgium’s preferred plan is two staged: PEPPOL-based structured 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. Under the Digital Reporting Requirement pillar, there is a planned mandatory structured e-invoicing requirement in the EU for intra-community supplies from 2028.
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Furthermore, it is not likely that governmental live reporting will be included as with Italy SdI or much of South America. The EU’s VAT in the Digital Age proposals preclude this.
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 B2G in Belgium. Although it’s not yet dedecided if Peppol would be the exclusive format.
The revised plan was made up of four stages:
- Jan 2024: companies must be able to receive e-invoices
- July 2024: Large taxpayers (turnover above €9 million)
- January 2025: Mid-sized taxpayers (turnover between €7m and €9m); and
- July 2025 (TBC): Small taxpayers below €7m
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.
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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.
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