In early March 2023, the Belgian Ministry of Finance confirmed that work was underway on major tax reform aimed at introducing nationwide mandatory e-invoicing and e-reporting for Belgian taxpayers. More details should be known in the summer of 2023, but it is likely that there will be some exceptions to the obligation.
E-reporting in Belgium
Belgium is following the activities of the European Commission and its announced proposals based on VIDA reform. VIDA will introduce an obligation to report all EU cross-border transactions to national tax authorities. In order to comply with the obligations imposed by VIDA and to fight the ever-growing VAT gap in the budget, Belgium will most likely decide to implement the following solutions:
- Mandatory e-reporting of sales transactions and purchases of goods and services within the EU - this will eliminate the need to submit recapitulative statements (EC sales list)
- Compulsory e-reporting of domestic sales and purchases - it is expected that the Annual Sales Listing will be withdrawn.
Therefore, it seems that e-reporting will cover a wider group of taxpayers than e-invoicing, including foreign companies registered for VAT in Belgium.
From 1 January 2026, e-reporting will apply to the majority of Belgian taxpayers, and other entities will be covered by it from 2028.
From 1 January 2024, the possibility of receiving invoices in electronic form will become mandatory in Belgium. Then, an obligation to issue e-invoices will be introduced, but it will be implemented gradually, depending on the size of the taxpayer.
It is expected that the PEPPOL network will be a standard for the exchange of electronic invoices in Belgium. The e-invoice will have to be a structured format in accordance with the European standard EN 16931. As a result, a PDF file will no longer be considered an electronic invoice.