New VAT chain partially postponed: what takes effect and what doesn't?

Late last year, we reported on a number of significant changes to VAT procedures for, among other things, the filing and payment of VAT returns (the so-called "VAT chain"). The introduction of the new VAT chain would be phased in by 2025, with some changes taking effect immediately and others at a later date.

A key pivot date was October 1, 2025, when the current account would be replaced by the commission account. Due to the FPS Finance not getting its systems updated in time, certain aspects of the new VAT chain are now being delayed until further notice and transitional measures are also provided.

So as not to lose track, we once again list what will be retained and what will be deferred.

Declaration and payment deadlines

Since Jan. 1, 2025 quarterly employers about a longer filing and payment period for filing the periodic VAT return and IC statement, namely the 25th of the month following the quarter instead of the 20th. The same deadline also applies to the filing of the special declaration.

The submission and payment deadline for MONDAY retained on the 20th of the month following the reporting period. On the other hand, it does allow for faster refunds of VAT credits without still requiring a permit monthly refund.

This additional flexibility was accompanied by the extinction of some tolerances created by the administration in the past to provide additional relief to companies to meet their obligations on time in certain cases. The elimination of these tolerances is postponed as a transitional measure until date of introduction of the full VAT chain.

Specifically, therefore, the following tolerances apply back:

• The non-imposition of late filing penalties of a VAT return, provided that such return is filed by the 10th day of the second month following the reporting period;
• The vacation scheme In which taxpayers are required to pay annually in the summer period be given more time to file their returns. Should the new VAT chain not be in place before the summer of 2026, there will again be an extended filing period for Q2, July and August returns;
• The renew of the deadline for submission and payment if the deadline does not fall on a business day, in the weekend or on a official holiday. This tolerance was no longer applicable to quarterly providers since October, but will now continue to apply to this group of taxpayers for the time being.

Payment methods

The previously envisioned introduction of the commission account meant that VAT due that showed up on a return filed after 30/06/2025 had to be paid into a new bank account number of the administration.

This is also postponed indefinitely, so account number BE22 6792 0030 0047 of the 'VAT Receipts' in Brussels with the known structured communication must continue to be used. Deposits to the new account number will be refunded and will result in a late payment.

Substitute declaration and sanctioning

If a company has not filed a return 3 months after the deadline for filing, the administration will provisionally file the Determine VAT due based on a substitute return, in which the VAT liability will be equal to the highest amount due as evidenced by returns filed in the previous 12 months, with a minimum of €2,100.

This mode of operation is applicable since 2025 and is preserved. Upon receipt of such replacement declaration, the company has 1 month time to still file a return. If not, the amount of the replacement return becomes due. The administration will usually proceed with a control To determine the exact amount.

In the event that a return is not filed and/or paid on time, starting Jan. 1, 2025 new sanctions applicable that also apply stay. In summary, it is about the following:

• 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.

Maintaining current account and refund procedure

Every VAT taxpayer has a current account with the FPS Finance in which all the VAT debts and VAT credits be enrolled, the so-called current account. In certain cases, amounts in this account were transferred to a special account, if, for example, debts were not paid or there was a remaining balance when operations ceased.

On 01/10/2025, the current account would be replaced by a commission account. This provision account would only hold balances for which no reimbursement was requested in the periodic declaration, for which the reimbursement conditions were not met and any advances paid by the company. The assets in the commission account could then only be reclaimed via MyMinfin and no longer through the application for a refund in the periodic return.

The introduction of the commission account appears technically more complex than thought, so that even after 30/09/2025 the (special) account and its operation will be maintained. Specifically, when a company checks the "request a refund" box in its periodic return, the refund covers both the return balance and the full outstanding balance in the current account.