The start of 2025 brought the long-awaited rollout of the new vat chain with it. This chain includes the rules around VAT returns, (refund) payments and penalties for companies subject to VAT. The changes will be phased in and affect any business subject to VAT.

New declaration and payment deadlines

Longer declaration deadline for quarterly employers

Until the end of 2024, taxable enterprises were always required to submit their VAT returns, monthly or quarterly, by the latest on the 20th of the month following the declaration period. This deadline is retained from 2025 for monthlies but becomes extended for quarterly employers to the 25th of the month following the quarter to be reported. Quarterly filers are thus given more time to file their returns, monthly filers are not.

The new return deadline does not only relate to the periodic VAT return but also on the other returns including the IC return and special VAT return.

Longer payment period for quarterly originators, faster refund of credits for monthly originators

The payment terms change along the same lines so that quarterly employers from 2025 also five additional days get to pay the balance due shown on the return. Monthly filers should still make their payment no later than the 20th of the following month.

Nevertheless, enjoy MONDAY of an additional benefit in case the return results in a credit and they claim a refund for it. This credit is refunded no later than the second month following the declaration period instead of the third month for quarterly providers. Every monthly principal can enjoy this faster refund period. The permit monthly refund was therefore abolished.

New payment methods

As of October 2025, New bank account numbers put into use for payment of VAT debts. So it is important to make the necessary adjustments in your (payment) systems around that time! Until then, the old account numbers will remain in use and payments should be made as before.

In addition, it will from 2026 become possible to pay VAT debts by direct debit to eliminate any risk of late payment.

The price tag: elimination of tolerances and tougher sanctions

Against this additional flexibility, there are also a number of changes that play in the tax authorities' favor. The filing and payment deadlines will henceforth be strictly applied without restriction as to what the elimination of existing tolerances involves as well as the imposition of stricter sanctions. In the event of failure to file a return, the administration will now also be able to substitute a substitute return.

Elimination of tolerances

Following tolerances will expire as of 01/01/2025:

• Not imposing penalties for late filing of a VAT return provided the return is filed by the 10th day of the second month following the return period. As a transitional arrangement, this tolerance will lapse for declarations legally required to be filed after 01/10/2025. Moreover, after this date, a one-time waiver of the fine can also be obtained for a first offense;
• The vacation rule under which taxpayers are given more time each year during the summer period to file and, in certain returns, pay their returns. As a transitional arrangement, the administration will institute a summer arrangement one last time in 2025;
• Extending the filing and payment deadline if the deadline does not fall on business day. This tolerance expires only for quarterly principals and also comes with a transition period in 2025: 25/01 becomes 27/01, 20/04 becomes 22/04, 20/07 becomes 22/07 and 20/09 becomes 22/09.

Sanctioning

If a return is not filed and/or paid on time, the following penalties will apply as of 01/01/2025:

• Late filing penalty (<5m delay): €100 to €500 per month of delay, per declaration;
• Penalty non-filing of declaration (>5m delay): €500 to €5,000 per declaration;
• Penalty late payment or non-payment: 5% VAT due from timely filed return, 10% VAT due from late filed return and 15% VAT due from final replacement return;
• Late payment interest of 8% per year, immediately upon each late payment.
• For repeat violations, a reference period of 4 years prior to the violation is taken into account. Offenses committed as of 01/01/2025 are taken into account.

Substitute declaration

If a company has not filed a return 3 months after the filing deadline, the administration will Provisionally determine the VAT due based on a substitute declaration where the VAT debt will be equal to the highest amount owed evidenced by returns filed in the previous 12 months with a minimum of €2,100.

Upon receipt of such a substitute return, the company has 1 month to still file a return if not, the amount of the substitute return becomes due. The administration will usually proceed with an audit to determine the exact amount.

Goodbye current account, welcome commission account

The commission account as a replacement for the current account

Every VAT taxpayer has a current account with the FPS Finance in which all VAT debts and VAT credits are registered, the so-called current account. In certain cases, amounts in this account were transferred to a special account if, for example, the payment of debts was not forthcoming or there was still a remaining balance when activities ceased.

As of 01/05/2025, the current account will be replaced by a commission account. On this provision account the amounts due will no longer be registered as well as the assets for which a refund was requested through the declaration. Only assets for which no refund has been claimed in the declaration or for which the conditions have not been satisfied as well as payments made by the company in anticipation of a balance to be paid from a future declaration (advances) will be recorded in this account. The entry is made after the expiration of the repayment period, 2 and 3 months respectively following the declaration period for monthly and quarterly principals. During this period, the administration always has the opportunity to check the correctness of the amount and correct it if necessary.

Use of available commissions

The commission account therefore only contains balances and the balance can also only be retrieved via a new online application on MyMinfin. This can be done at any time after which the reimbursement takes place within 30 days. Unlike in the past, the request for reimbursement of a balance in a periodic declaration will only relate to the balance shown in box 72 of the declaration and no longer to the entire balance that may also be on the commission account. From then on, the credit will only be refunded if the company has always submitted its VAT returns on time during the previous six months.

The funds in the provision account will automatically be used by the tax authorities for the payment of VAT debts and any fines and interest on arrears resulting from timely or non-timely filed returns as well as substitute returns. The funds can also be used for uncontested VAT debts for which a company would still be liable. The operation of the provision account will eventually be extended so that VAT credits can also be used to pay other tax debts and prepayments.

Transitional

Refunds requested via declarations with legal filing date before 01/05/2025 will still go through the old current account procedure. After that, any balance is transferred to the commission account and the new rules apply.

It is clear that the introduction of the new VAT chain entails a number of important changes in terms of filing returns and (re)payment of balances. If you have further questions or would like more information on certain aspects, please contact one of our experts.