How does e-invoicing work for mixed VAT taxpayers?

If, as a self-employed person, you carry out both activities that are subject to VAT and activities that are exempt from VAT, you’re a mixed VAT taxpayer. If this is the case, you only need to send electronic invoices for your activities that are subject to VAT.

Who needs to use e-invoicing?

Starting in 2026, all Belgian businesses subject to VAT will be required to send electronic invoices via Peppol. Or at least, for all B2B transactions, i.e. invoices between businesses. There's no obligation to send electronic invoices to private individuals.

Note that the switch to electronic invoicing from 2026 is also mandatory for those who are self-employed in a secondary occupation and for businesses that operate under the VAT exemption scheme for small businesses if they invoice other Belgian business clients. Read more in this article.

What is mixed VAT liability?

You’re subject to mixed VAT if you carry out both VAT-exempt activities and activities that are subject to VAT.

Article 44 of the VAT Code contains a list of liberal professions exempt from VAT. Do you combine one of these liberal professions with activities that are subject to VAT? If so, you’re subject to mixed VAT liability. Here are some examples:

• a dentist or physiotherapist who also sells products
• an accountant who also provides training
• an educational institution that also sells educational materials
• a psychologist who, in addition to consultations, organises workshops

Worth knowing when you’re subject to mixed VAT

Invoicing and VAT declarations are a little more complicated when you’re self-employed and subject to mixed VAT liability.

On your invoices and VAT declarations, you need to clearly distinguish between goods and services that are subject to VAT and those that are exempt, and correctly calculate your VAT deduction.

• Invoices: For goods and services exempt from VAT, clearly state ‘Exempt from VAT under Article 44 of the VAT Code’ (‘Exempté de TVA en vertu de l’article 44 du Code de la TVA’ / ‘Vrijstelling van btw overeenkomstig artikel 44 van het btw-wetboek’). For goods and services subject to VAT, charge the correct VAT rate (6%, 12% or 21%).
• VAT deduction: You can calculate your VAT deduction based on a ratio (based on your turnover) or your actual usage (based on the purpose of the expenditure).

Want to know more about mixed VAT liability? Read this article about invoicing, VAT deduction, and VAT returns for mixed VAT taxpayers.

Electronic invoicing and mixed VAT liability

Are you self-employed with mixed VAT liability, and you send invoices to other Belgian businesses? In this case, from 1 January 2026, you’ll be required to send electronic invoices via Peppol for your VAT-registered activities.

Do you invoice businesses elsewhere in the EU? For now, you're not required to send electronic invoices to those clients. Read more about e-invoicing when you have clients in other EU countries.

Register for free on the Peppol network and easily send electronic invoices, manage your accounting, and prepare your VAT returns with Accountable.

Author - Alexis Eggermont

Alexis is co-founder at Accountable. He is passionate about leveraging data, AI, technology, and entrepreneurship.

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