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As from 1 January 2025, EU Member States are authorized to extend the VAT exemption scheme for small enterprises. This implies that Belgian taxable persons with limited turnover can expand their operations abroad without being obliged to register for VAT or submit VAT returns in those countries. The same applies for non-Belgian entities carrying-out economic activities in Belgium.
Current rules
To date, EU Member States are (only) allowed to exempt small enterprises established in that EU Member State from the obligation to charge VAT (and thus register for VAT and file VAT returns), provided that the annual turnover does not exceed the maximum threshold (€25.000 in Belgium).
As from 2025
As from 2025 a double yearly threshold will apply in order to benefit from the VAT exemption scheme for small enterprises:
- A local threshold in the EU Member State of establishment (maximum €85.000 – €25.000 for Belgium);
- An EU threshold of €100.000: small enterprises established in another EU Member State than where the VAT becomes due do not have to register in that EU Member State provided that:
- The national threshold is not exceeded;
- The annual turnover across the EU is lower than €100.000.
Note that non-EU businesses cannot benefit from the exemption scheme for small enterprises and are thus still liable for VAT as from the first sale in the EU.
Notification duty
In addition to the notification of the application of the exemption scheme for small enterprises via the form e-604A or e-604b towards the Belgian VAT Authorities, an additional notification must be done in order to benefit from this regime in other EU Member States, whereby the Belgian VAT number will be extended with the suffice “EX” (BE 0123.456.789 EX).
The following information must be provided:
- The EU Member States in which the taxable person intends to apply the exemption scheme for small enterprises;
- The total turnover in Belgium and in each of the respective other EU Member States.
Any changes in this respect must be notified upfront to the Belgian VAT Authorities.
Declarations
In order to monitor the thresholds, quarterly VAT returns must be submitted, indicating the turnover obtained in Belgium and in any other EU Member State (indicating “0” where appropriate).
Belgian small enterprises are also liable to submit an annual client listing. As from 2025, this annual client listing must include all turnover (even if customers do not have a VAT identification number).
If you have any questions regarding this topic, don’t hesitate to contact our RSM Belgium | Tax team ([email protected]).
