Failure to agree major tax reforms means July 2024 mandatory B2B e-invoicing launch abandoned; January 2026 likely
The collapse on agreement for a major Belgian tax reforms means that the July 2024 plans to launch mandatory VAT e-invoicing has now been withdrawn. The reforms, which refer to the Belgian Peppol-based real-time reporting regime, had envisaged a major shift of the tax burden away from income to wealth. But opposition parties doubted the government’s estimates on the likely new revenues and the risk of a shortfall. Failure to agree on the tax plan means any fresh attempt to push the reforms will not come until after the 2024 summer elections.
The Belgian Ministry of Finance has said it will return to this issue after the summer’s break; but gathering political agreement means no mandate is likely before 2026. The government will also wish to see the progress of the EU’s e-invoicing plans in ‘ViDA’ which faces its own potential delays.
Belgium is aiming for a 5-corner Peppol-model.
5 Mar 2023: Ministry of Finance planned July 2024 to July 2025 B2B invoicing phased rollout; Full govt and Parliament approval was needed
Belgium’s Ministry of Finance had 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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4-stage proposed implementation (now abandoned)
The 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
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.
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 2026 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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