Belgium requires all VAT payers to file an annual return with details about all domestic sales made in Belgium during the previous calendar year. This return, commonly referred to as the annual sales listing, includes detailed information about the sales made to VAT registered customers in Belgium. The deadline for filing this return is rapidly approaching and fines can be imposed for late filing.
What?
The annual sales listing contains the details of the Belgian VAT liable clients to which, during calendar year 2018, goods or services amounting to a value of more than EUR 250,00 (excl. VAT) have been provided.
For each client that is included in this listing, the customer name, the VAT number, the total net amount of sales and the total VAT amount (if any) have to be mentioned. This information must be provided for each different VAT number.
If there were no sales to be included in the annual sales listing for calendar year 2018, the VAT payer still has to file a nil listing. However, no separate listing has to be filed if the box for a nil listing is ticked in the December 2018 VAT return (or the VAT return for the 4th quarter of 2018).
Who?
In principle, all VAT payers have to file the listing. However, enterprises that only conduct activities that are exempted from VAT (according to article 44 of the Belgian VAT Code) are exempted from the obligation to file the annual sales listing.
Enterprises that conduct exempted activities as well as VAT liable activities still have to file an annual sales listing, but they can exclude the VAT exempted sales from this listing.
Finally, enterprises that are part of a VAT group have to file the annual sales listing per separate member of the VAT group and have to include qualifying transactions between the members of the VAT group.
When?
The due date to submit the annual sales listing for calendar year 2018 is 31 March 2019.
If the annual sales listing is submitted late, a fine can be imposed. This fine can range between EUR 75 and EUR 1.500 if the listing is filed within 3 months after the due date, and between EUR 225 and EUR 2.250 if the listing is filed within 3 to 9 months after the due date and, finally, if the listing is filed after this period or not filed at all, a fine of EUR 3.000 can be imposed.
How?
The annual sales listing has to be filed electronically via Intervat.
We are happy to assist in case you need some support to extract the data out of your ERP system, to convert the data into the right XML format or to file the listing as such. Please do not hesitate to reach out to your local PwC contact person.
