As of January 1, 2025, new legislation has come into force aimed at simplifying and optimizing the VAT chain (the mechanism by which VAT is collected and deductible at each stage of the supply of goods or services to an end user).
The main goal is to streamline procedures and make them more efficient for both businesses and the tax administration. Below is a comparative table with the key measures before and after the entry into force of this new VAT legislation.
Filing and Payment Deadlines
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Monthly filers:
- Before: Deadline: the 20th of the month following the reporting period
- After: Deadline unchanged
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Quarterly filers:
- Before: Deadline: the 20th of the month following the reporting period
- After: Deadline: the 25th of the month following the reporting period
Administrative Tolerance
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Holiday arrangement:
- Before: Tolerance for the months of June and July
- After: Tolerance abolished (transition period: summer 2025)
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Extension of filing deadline to next business day:
- Before: Extension allowed if the deadline falls on a Saturday, Sunday, or public holiday (for monthly and quarterly filers)
- After: Maintained for monthly filers, abolished for quarterly filers (from October 1, 2025)
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Correction of a material error:
- Before: Possible to overwrite a previous return within 12 months via Intervat
- After: Correction must be made in the next periodic VAT return
Substitute VAT Return
- Before: Not applicable
- After: Introduced if no return is filed after 3 months; the highest VAT amount from the past 12 months or a minimum of EUR 2,100 will be charged
Request for Information
- Before: No response deadline
- After: One-month response deadline (extension possible); in some cases, limited to 10 days (e.g., VAT refund audit, treasury risk)
New Provision Account
- Before: Use of the current account
- After: Replaced by a provision account funded by non-refunded VAT credits and prepayments; used by the FPS Finance to settle VAT debts
Refund of VAT Credit
- Before: Full refund of the current account balance via the periodic return
- After: From October 1, 2025, refund limited to the VAT credit in the return, subject to conditions (timely ad hoc filing, previous 6 months’ returns, minimum EUR 50, timely bank account notification via E-604A or E-604B)
Penalties
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Before:
- No return: EUR 1,000 per return
- Late return: EUR 100/month (max. EUR 1,000)
- No proportional fine for non-payment (except with special account)
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After:
- No return: EUR 500 to EUR 5,000 per return
- Late return: EUR 100 to EUR 500 per month
- Non-payment: proportional fine of 5% to 15%
Ex Officio Assessment
- Before: Requires intervention of the Minister of Finance or representative
- After: Can be carried out by the VAT administration itself
Account Numbers and Payment Methods
- Before: VAT account numbers depend on the taxpayer’s registered office
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After (from October 1, 2025):
- Payment without enforceable title: BE41 6792 0036 4210
- Payment after enforceable title: BE41 6792 0000 0054
- Direct debit via bank transfer available from early 2026
