Belgian VAT Chain Modernisation

As from 1 May 2026, the next phase of the Belgian VAT chain modernisation becomes operational. A key element of this reform is the replacement of the traditional VAT current account by a VAT provision account. This change is part of a broader digitalization project aimed at improving transparency, flexibility and compliance in the management of VAT positions with the Belgian VAT Authorities.

These changes follow the law of 1 January 2025 on the modernisation of the VAT chain and the collection of fiscal and non-fiscal debts.
 

ENTRY INTO FORCE

01 May 2026
 

AMENDMENT OF THE SYSTEM

Under the previous system, VAT credits and VAT debts were managed through the VAT current account, which functioned as the central account for settlement, refund and offsetting purposes.

As from 1 May 2026, this system is replaced by the VAT provision account. This account is a bookkeeping instrument held by the VAT Authorities in the name of each taxable person in which VAT credits, payments and other relevant amounts are recorded.

In accordance with article 47 of the Belgian VAT Code, any excess input VAT for which no refund is requested is automatically transferred to the VAT provision account. In addition, pursuant to article 76, §1 of the Belgian VAT Code, VAT credits for which the conditions for refund are not met are also recorded on this account.

The VAT provision account centralises all VAT receivables and payables and allows taxable persons to monitor their overall VAT position via MyMinfin. The VAT return for April 2026 for monthly filers and for the second quarter of 2026 for quarterly filers will be the first returns processed under this new system. From that date, new bank account numbers must also be used for VAT payments.
 

VAT REFUNDS

The reform introduces an important change regarding the recovery of VAT credits. Where a refund is requested through the periodic VAT return, the refundable amount is limited to the amount reported in box 72 of that return. This implies that the taxable person must explicitly indicate in the VAT return for which amount the refund is requested.

Where no refund is requested or where the conditions for refund are not fulfilled, the VAT credit is not automatically paid out but remains available on the VAT provision account. The taxable person may subsequently request the refund of the available balance via MyMinfin, subject to the applicable conditions.

It should also be noted that the amounts recorded on the VAT provision account do not qualify as immediately recoverable claims against the State and may be used by the VAT Authorities to offset amounts due, including VAT debts, fines, interest and costs as well as other non-VAT related debts.
 

NEW BANK ACCOUNT NUMBER

As part of this reform, VAT payments must as from 1 May 2026 be made to a new bank account number introduced by the Belgian VAT Authorities, namely BE41 6792 0036 4210. Taxable persons should ensure that their payment templates, standing orders and internal processes are updated accordingly, as payments made to the former bank account numbers may no longer be correctly allocated to their VAT position and could give rise to late payment interest or administrative follow-up.
 

TRANSITIONAL MEASURES

Any VAT credit available on the VAT current account as of 30 April 2026 will in principle be automatically transferred to the VAT provision account.

Where one or more VAT returns are still outstanding at that date, the VAT Authorities will first allow a period for the submission of the missing returns before assessing whether the credit can be refunded or must be used to offset outstanding debts.
 

ABOLITION OF THE VAT SUMMER REGIME

As part of the modernisation, the traditional VAT summer or holiday regime is abolished. For the year 2026, a tolerance measure applies whereby no penalties will be imposed for late filing where returns are submitted within the deadlines that would have applied under the former regime.
 

ADDITIONAL COMPLIANCE MEASURES

In addition to the introduction of the VAT provision account, it introduces several measures aimed at strengthening compliance. Where a periodic VAT return is not submitted within the legal deadline, the VAT Authorities may issue a proposal for a substitute VAT return after a period of three months. This proposal is based on the highest VAT amount declared in the previous twelve months, subject to a minimum amount of 2.100 EUR and becomes definitive if the taxable person does not react within the prescribed period.

Furthermore, taxable persons are subject to a general deadline of one month to respond to requests for information from the VAT Authorities, which may be reduced to ten days when the rights of the Treasury are at risk or in the context of VAT credit verification.
 

CONCLUSION

The introduction of the VAT provision account fundamentally changes the way VAT positions are administered in Belgium. While the reform aims to provide greater transparency and centralisation, it also requires taxable persons to take a more active role in managing their VAT position.

In particular, VAT credits are no longer automatically refundable and may be offset against outstanding debts, which may have an impact on cash flow. In addition, stricter compliance rules increase the importance of timely and accurate VAT reporting.

A careful follow-up of the VAT provision account and timely compliance with the new requirements will be essential in order to avoid cash flow disadvantages or administrative complications.
 

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.