In-House Tax Forum welcomes Belgium’s VAT e-reporting step — and urges a move to supplier-only reporting
The In-House Tax Forum (“IHTF’’)[1] has taken note of the draft law approved by the Council of Ministers on 18 July 2026. This draft introduces a new obligation for businesses to report their domestic business-to-business (B2B) transactions electronically, and it removes the requirement to file the annual client listing (the yearly summary of Belgian customers each business must currently submit).
We welcome this as an important step in modernising and digitalising VAT compliance. In particular, we appreciate the removal of the annual client listing, which is a real and genuinely helpful simplification for businesses.
IHTF fully supports the Government’s goals: reducing the “VAT gap” (the difference between the VAT that should be collected and what is actually collected), improving the quality of tax data, and preparing Belgium for the EU’s upcoming “VAT in the Digital Age” (ViDA) reform. We remain firmly committed to working constructively with FPS Finance.
That said, we would like to repeat our single, central point: the obligation to report a transaction should fall on the seller (supplier) only.
As the draft is currently written, it uses a “two-sided” model, meaning both the seller and the buyer (customer) have to report the same transaction. We see three problems with this:
- Duplication with no added value. The customer would simply be re-sending information the supplier has already reported, without providing any independent check.
- Data that won’t match. The customer’s figures will almost inevitably differ from their own accounting records and their periodic VAT return, creating mismatches.
- A disproportionate burden, especially given the very short deadline businesses would have to report.
Requiring the customer to report as well goes further than ViDA actually asks for, and it risks pulling Belgium out of step with the rest of Europe, undermining the goal of harmonised EU rules.
Our concern is even greater for a specific type of transaction covered by Article 194 of the EU VAT Directive. In simple terms, Article 194 covers situations where the customer — rather than the supplier — is the one responsible for paying the VAT to the tax authorities (this is known as a “reverse charge”). The draft plans to require dual reporting of these transactions from 1 July 2028. When you combine that with the existing EC Sales Listing (the report of cross-border EU sales), the very same transaction would end up being reported three separate times. This directly contradicts the widely accepted “report only once” principle.
As the draft now moves on to the Data Protection Authority and the Council of State for review, we believe there is a valuable opportunity to reconsider who should have to report. We are ready to share the practical, hands-on experience of our members to help get this right.
We also renew our request for a realistic timeline. Businesses need at least one year of lead time starting only from the moment all the rules and IT/technical requirements are final and stable. This is even more important if the separate SAF-T reporting package (a standardised electronic file of a company’s accounting data) also goes ahead in parallel from 2028.
IHTF looks forward to continuing this conversation in a spirit of partnership, in our shared interest of building a Belgian VAT system that is effective, fair and proportionate, and ready for the future.
On behalf of the In-House Tax Forum
July 23, 2026
[1] The In-House Tax Forum (“IHTF”) is a non-profit organization based in Belgium, the heart of Europe, creating an informal network of in-house tax experts focusing on direct and indirect tax legislation and developments. The IHTF comprise 400+ tax experts from over 130 companies out of various industries. Website: www.ihtf.be
