VAT, interactive virtual trainings and place of supply

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In this article, you will find:

• where the service is located for VAT purposes,

• when you must charge Belgian VAT,

• when foreign VAT may apply,

• and what this means in Accountable.

This article applies if

This article covers situations where:

• you organise a live online training,

• participants can interact in real time,

• you host a virtual or streamed event with direct interaction.

In these cases, human intervention is considered essential. These services are therefore not treated as simple electronically supplied services.

What changed for interactive virtual trainings?

Since 31 December 2025, the VAT place of supply rules applicable to interactive virtual trainings and streamed events with interactive participation have changed.

The place of supply is no longer determined by where the activity is carried out, but by the country in which the recipient of the service is established.

This new rule applies in both B2B and B2C situations.

What does “place of supply” mean?

The place of supply is the country in which the service is considered to be supplied for VAT purposes.

• If the place of supply is in Belgium, Belgian VAT applies.

• If the place of supply is in another EU country, that country’s VAT rules apply.

• If the place of supply is outside the EU, no Belgian VAT is due.

How did this work before?

Before this change, the place of supply of interactive virtual trainings was determined by where the activity was actually carried out. In practice, this usually meant the country in which the supplier was established.

In concrete terms, when an organiser was established in Belgium, they generally had to charge 21% Belgian VAT, whether the customer was a business or a private individual, and whether the customer was established in the EU or outside the EU.

What is the rule today?

Today, for interactive virtual trainings and streamed events with interactive participation, the place of supply is determined by the country in which the recipient of the service is established.

In practice, this means that a Belgian organiser still charges 21% Belgian VAT only when the customer is established in Belgium. In all other cases, you must analyse the customer’s country and status, business or private individual.

Examples

1. You sell to a business established in another EU country (B2B)

If a Belgian company provides an interactive virtual training to a Dutch company, the service is located in the Netherlands, meaning in the Member State where the recipient is established.

In this case:

• you do not charge Belgian VAT,

• you mention “Reverse charge” on the invoice,

• the taxable customer accounts for the VAT in their own country,

• the amount must be reported in grid 44 of the Belgian VAT return,

• and under code “S” in the Intracom listing.

2. You sell to a private individual located in another EU country (B2C)

If a Belgian company provides an interactive virtual training to a private individual located in another EU country, the service is located in the customer’s country.

Reverse charge is not possible in this case. You must therefore charge the VAT of the customer’s country.

In practice, this implies:

• either a local VAT registration in the customer’s country,

• or the use of the OSS scheme.

3. You sell to a customer located outside the EU

If the customer, whether a business or a private individual, is established outside the European Union, no VAT is due.

In Accountable, the invoice automatically includes the legal mention “Article 39 – export of services” by default for this type of situation.

Special case: on-demand video training

An on-demand video training is in principle considered an electronic service.

It is supplied via the internet, in a mainly automated way, with little or no direct human intervention.

In this case, the rules are not the same as for a live interactive virtual training.

If you sell to a private individual located in another EU country

As long as the annual total of the relevant sales remains below or equal to €10,000, you may in principle continue to charge Belgian VAT.

Once this threshold is exceeded, the service is in principle taxed in the customer’s country.

In practice, after exceeding the threshold:

• you must apply the VAT rate of the customer’s country,

• either through a local VAT registration,

• or through the OSS scheme.

Summary depending on the type of content sold

The key distinction is therefore the following:

• the €10,000 threshold may apply to on-demand video trainings where they qualify as electronic services,

• but it does not apply to live interactive virtual trainings or interactive virtual events.

Key takeaway

For interactive virtual trainings and streamed events with interactive participation, a Belgian supplier only charges 21% Belgian VAT where the customer is established in Belgium.

In all other cases, the place of supply depends on the customer’s country.

For B2B EU, the reverse charge mechanism generally applies.

For B2C EU, you must charge the VAT of the customer’s country, usually via OSS or through a local VAT registration.

By contrast, for an on-demand video training, the €10,000 threshold may allow Belgian VAT to continue to apply as long as that threshold is not exceeded, because this is in principle an electronic service.

Author - Valesca Wilms

As content marketing lead at Accountable Belgium, Valesca writes about freelancing, self-employment, and taxes based on her own experience as a freelancer.

Who is Valesca ?