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As from 31 December 2025, new VAT rules will enter into force in Belgium for services consisting of granting access to events and activities. The legislation now distinguishes between physical and virtual participation, both in a B2B and a B2C context. These changes have a direct impact on the determination of the place of supply of such services and, consequently, on the VAT due. These amendments result from the transposition of Directive (EU) 2022/542 and are further explained in Circular Letter 2026/C/16 issued by the Belgian VAT Authorities.
ENTRY INTO FORCE
31/12/2025
AMENDMENT OF THE LEGISLATION
Under the former rules, the service consisting in granting access to an event and the services ancillary thereto was, for VAT purposes, deemed to take place where the event or activity actually was held. No distinction was made depending on whether participation was physical or virtual, nor on whether the participant was a taxable person or not.
The new rules make a distinction between physical and virtual participation, both in a B2B and in a B2C context.
PLACE OF SUPPLY IN A B2B CONTEXT
Under the new rules, the place of supply for B2B event-related services is divided into two categories:
- exclusively physical;
- exclusively virtual.
From now on, the specific place-of-supply rule whereby the service takes place where the event is held remains applicable only where the event can be attended exclusively in physical form (art. 21, §3, 3° of the Belgian VAT Code).
Where access to the event is provided virtually, the place of supply of the service is determined in accordance with the general rule for B2B services, specifically at the place of the customer’s seat of economic activity or, where applicable, at the place of the fixed establishment or the usual place of residence of the taxable person (art. 21, §2 of the Belgian VAT Code).
Where an event can be attended both physically and virtually, it is decisive whether, at the time of issuing the invoice, the supplier knows in which way the customer will participate.
- If the supplier knows that the customer will participate physically, the service is located at the place where the event is held.
- If the supplier knows that the customer will participate virtually, the place of supply of the service is the seat of economic activity of the customer or, where applicable, the fixed establishment or the actual place of residence.
- If, at the time of invoicing, the supplier does not know in which way the customer will participate, the place of supply of the service is where the event is held. If it later appears that the customer attended the event virtually, the invoice must be corrected.
PLACE OF SUPPLY IN A B2C CONTEXT
For events or activities supplied to non-taxable people, the place of supply is also subdivided into two categories:
- exclusively physical;
- exclusively virtual.
In addition to the existing rule (art. 21bis, §2, 5° of the Belgian VAT Code), whereby the place of supply of the service is determined by the place where the event physically takes place, a new derogating rule is introduced for virtual events.
Where access relates to events or activities that are streamed or otherwise made available virtually, the service is therefore located at the place where the non-taxable person is established or has his place of residence or usual place of stay (art. 21bis, §2, 5°, second paragraph (new) of the Belgian VAT Code).
Here as well, in the case of hybrid events, the known way of participation at the time of invoicing is decisive, with a possible obligation to revise the invoicing if it subsequently appears that the participation was virtual.
CONCLUSION
The new legislation impacts the VAT treatment of services granting access to events, in particular where these are offered virtually or in a hybrid format. The place of VAT taxation may therefore differ depending on the form of participation. Clearly determining the mode of participation is therefore essential in order to invoice correctly and to limit subsequent VAT corrections.
In addition, these amendments also ensure that organisers of online events will have the obligation to charge foreign VAT where they provide access to online events in a B2C context. A foreign VAT registration or a One Stop Shop registration cannot be avoided in this respect.
If you require further information on this topic or assistance with VAT matters, the tax team of RSM Belgium remains at your disposal via tax@rsmbelgium.be.
