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🧾 What is the special VAT return for?

If you're self-employed and you don't file periodic VAT returns, you may sometimes need to file a special VAT return. This is the case when you receive services from providers established abroad, inside or outside the EU, or when you buy goods from suppliers established in another country of the European Union.
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For example, when you buy goods from an EU supplier and give them your Belgian VAT number, they treat you as a VAT-registered business. They then apply the intra-Community reverse charge and invoice you without VAT. It's then up to you to declare and pay the Belgian VAT on that purchase, through the special VAT return.
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In short: this return only concerns self-employed people who don't file periodic returns. It's used to declare certain purchases and services received (never your sales) on which Belgian VAT is due. Under these schemes, this VAT can't be recovered.

🐣 The special VAT return in 2 minutes

You're under the VAT exemption scheme for small businesses (or exempt under Article 44): you don't charge VAT and you don't recover VAT on your purchases. In principle, you therefore don't have any periodic VAT return to file.
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There's one exception: certain purchases from abroad. In some cases, Belgian VAT is due on these purchases, and you're the one who pays it, through the special VAT return.
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1. You buy a service from a foreign provider, inside or outside the EU (online advertising, software, online training...)
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You always give your VAT number and you always pay Belgian VAT, from the very first euro, whatever the amount. These services don't count towards the €11,200 threshold and don't commit you for your purchases of goods.

Exceptions:

• hotels and other services linked to a property located abroad;

• restaurants;

• passenger transport;

• admission to an on-site event;

• renting a vehicle for 30 days or less.

In those cases, the VAT of that country applies. A VAT-exempt service (an insurance policy, for example) doesn't give rise to Belgian VAT.

2. You buy goods in the EU (equipment, merchandise...)

• You don't give your VAT number: the supplier charges the VAT of their country, nothing to do in Belgium. This works as long as you've never given your VAT number for a purchase of goods, and your purchases of goods in the EU stay under €11,200 this year and were already under €11,200 last year.

• You give your VAT number, even just once: you pay Belgian VAT on all your purchases of goods in the EU, until 31 December of the second year that follows.

⚠️ This applies even if your regime on Intervat still shows VR.

🔎 Does your Intervat regime show VO although you never asked for this option (for example because of an error when you registered)? Contact your tax coach via the chat.

In short: what you need to do

💡 Belgian VAT to declare? You file one special VAT return per quarter, by the 25th of the following month at the latest, and the payment of this VAT must be in FPS Finance's bank account by that date. Accountable prepares the return for you based on your invoices.

📚 Learn more

The summary above covers most situations. The following sections explain each case in detail, with examples.

👥 Who needs to file a special VAT return?

Any taxable person or legal entity that doesn't file periodic VAT returns (monthly or quarterly), including:

• 🧑‍💼 Small businesses under the VAT exemption scheme

• 🌾 Farmers under the flat-rate scheme

• ⚖️ Taxable persons who only carry out exempt transactions (Article 44 of the VAT Code)

• 📜 Non-taxable legal entities (for example a municipality or a non-profit)

🔎 How do you check your VAT regime? Follow steps 1 to 4 of our article How to verify your VAT type when setting up your account on Accountable

⏰ When do you need to file a special VAT return?

1. ✉️ You receive a service from a provider established abroad (inside or outside the EU)

You must always:

• give your Belgian VAT number,

• declare and pay the Belgian VAT due, from the very first euro, whatever the amount.

🌍 The same rule applies to a provider established outside the EU, for example software invoiced from the United States: Belgian VAT is due and is declared in the special VAT return.

💡 The €11,200 threshold doesn't apply to services, and services don't count towards it. So check whether an invoice is for goods or for a service before entering it: online advertising or an online training course, for example, are services.

💡 Giving your VAT number for a service doesn't commit you for your purchases of goods: the commitment described below only applies to goods.

💡 If the service is VAT-exempt (for example insurance or certain financial services), no Belgian VAT is due.

⚠️ Exceptions: some services remain subject to the VAT of the country where they take place, whatever your situation (Art. 21, §3 of the VAT Code):

• hotels and other services linked to a property located abroad,

• restaurants and catering,

• passenger transport,

• admission to an on-site event (trade fair, exhibition, conference, seminar, training attended in person),

• short-term vehicle rental (30 days or less), taxed where the vehicle is handed over to you.

The provider then charges you the VAT of the country where the service takes place, and you have nothing to declare in Belgium.

2. 📦 You buy goods in another EU country (excluding new means of transport and excise goods)

📍 The €11,200 threshold

This threshold is the total of your intra-Community purchases of goods, across all countries and all suppliers, over a calendar year. It's not your turnover.

Purchases of goods in the EU aren't subject to Belgian VAT as long as this total doesn't exceed €11,200, neither in the current year nor in the previous year, and as long as you haven't opted for taxation in Belgium.

🧾 Case 1: your purchases stay under €11,200 and you've never given your VAT number for a purchase of goods

🧾 Case 2: your purchases go over €11,200

As soon as you go over the threshold, you must:

• give your Belgian VAT number to all your EU suppliers,

• declare and pay Belgian VAT through a special VAT return for each quarter in which you made a relevant purchase,

• notify FPS Finance before the purchase that takes you over the threshold, in principle through a change declaration (form 604B). This isn't needed if you already did so the previous year, or if you declared more than €11,200 of purchases of goods through your special VAT returns the previous year (Art. 53bis, §1 of the VAT Code).

🧠 Because the threshold is assessed over the current year and the previous year, the obligation applies for the rest of the year and the whole of the following year. It then continues as long as you go over the threshold again.

📌 Example 1: going over the threshold (no option)

Starting point: no purchases of goods in the EU in 2024, and VAT number never given before.

⚠️ In 2027, if you keep giving your VAT number when you no longer have to, you're considered to have opted (see Case 1).

📌 Example 2: presumed option (purchases under the threshold)

Starting point: purchases of goods in the EU always under €11,200 a year.

💡 Before giving your VAT number, check on the European Commission's VIES tool that both your VAT number and your supplier's are valid: the exemption applied by the supplier requires, among other things, that your VAT number is valid.

💡 The VO and SO regimes on Intervat

If your VAT regime on Intervat is:

• VO: exemption scheme (VR) with the option for intra-Community acquisitions,

• SO: exempt under Article 44 (SX) with the same option,

you've formally opted for Belgian VAT on your purchases of goods in the EU, from the very first euro, whatever the amount. The supplier invoices you without VAT, you declare the purchase and you pay the Belgian VAT, without being able to recover it.

❓ Why choose this option? It may be relevant if you frequently make purchases within the EU, if your suppliers require an intra-EU VAT number, or if you want to avoid tracking the €11,200 threshold.

⚠️ A VR or SX regime on Intervat only means that no option has been formally registered. For a small business under the exemption scheme (VR), if you've already given your VAT number for a purchase of goods, the presumed option still applies (see Case 1). If you're an exempt taxable person (SX) in this situation, contact your tax coach to check your case.

3. 🚗 You buy a new means of transport or an excise product

Belgian VAT is always due, whatever the amount:

• if you've already given your VAT number or gone over the threshold, you declare it through the special VAT return,

• otherwise, you declare and pay it to the General Administration of Customs and Excise (a dedicated special return for new means of transport, or an excise document for excise products).

These purchases don't count towards the €11,200 threshold that applies to other goods.

🚗 A vehicle is considered new if it's delivered within 6 months of first being put into service, or if it hasn't travelled more than 6,000 km. To register it with the DIV, you'll need the E705 signal, which you can get through MyMinfin.

🌍 What about purchases from outside the EU?

A purchase of goods from outside the EU (China, United States, United Kingdom...) isn't an intra-Community acquisition but an import. The goods go through customs and the import VAT is in principle paid at customs clearance, often advanced by the carrier, who then re-invoices it to you. It doesn't go through the special VAT return. If you're unsure about a shipment, contact your tax coach.

⚠️ Distance sales of imported goods: if you buy goods online that are shipped from a non-EU country (for example on an e-commerce platform), and you haven't gone over the €11,200 threshold or opted, you can't give your VAT number to the seller. Excise products aren't covered by this rule.

🧾 How to enter it in Accountable

When entering the invoice:

1. Select 0% VAT in the dropdown menu.

2. Select the reason for 0% VAT: "Intra-EU reverse charge regime" for an EU supplier, "This is a purchase from outside the EU" for a provider outside the EU.

3. For an EU supplier, select the applicable Belgian VAT rate: usually 21%, unless a reduced rate applies.

🔁 You forgot a transaction or your supplier charged you their VAT

The quarter hasn't been declared yet: generate and file the special VAT return for that quarter, even if it's late (see the section on late filing below).

The quarter has already been declared: the missing Belgian VAT must be regularised. Contact your tax coach via the chat before taking any steps: how to do it depends on your situation, and we'll check the amounts together.

Your supplier charged you the VAT of their country when Belgian VAT was due (for a service, or for goods if you went over the threshold or opted): Belgian VAT is still due through your special VAT return. The foreign VAT doesn't replace it. To get it back, ask your supplier for a credit note and a new invoice without VAT, showing your VAT number.

📅 Deadlines and frequency

• ⏳ One return per quarter

• ❌ No taxable transaction during the quarter: no nil return

• ⚡ Filing deadline: the 25th of the month following the end of the quarter

• 💵 Payment of the VAT due: the amount must be in FPS Finance's account by the 25th at the latest

💡 You can file the return up to and including the 25th. For the payment, allow for your bank's processing time: make the transfer a few working days before the 25th, especially if the 25th falls on a weekend or a public holiday.

💻 How to file the return

• Through Accountable, which generates the return from your invoices

• On Intervat, the online platform of FPS Finance

• On paper, if you can't or don't want to use Intervat

For the step-by-step guide: How do I submit a special VAT return or a declaration 629?

💡 Keep all your supporting documents (invoices, purchase orders) together, and remember that this VAT can't be recovered.

⚠️ What if you file or pay late?

Late filing

• ✅ If you file the return spontaneously, even late, no fine is imposed (administrative tolerance of FPS Finance).

• ✅ If you receive a reminder letter and file within 30 days, no fine is imposed either.

• 🚫 If you don't file, or file after that 30-day period, a fine may be imposed.

Late payment

• 💸 Late payment interest is due on VAT paid late.

• ⚖️ A proportional fine may also apply. It may be waived in full if you correct the situation spontaneously, before any action by the tax authorities.

💡 Forgot some returns? The sooner the better: file and pay before you receive a reminder.

🧠 Key takeaways

• 🔹 You can't recover the VAT paid through the special VAT return, but you can add it as a business expense, in the same category as the original cost.

• 🔹 You only declare the relevant purchases and services received, never your sales.

• 🔹 Services from a foreign provider (inside or outside the EU) are taxed in Belgium from the very first euro, whatever the amount, except for the exceptions (hotels, restaurants, passenger transport, on-site events, short-term vehicle rental) and exempt services.

• 🔹 For goods, giving your VAT number just once commits you until 31 December of the second year that follows.

• 🔹 One return per quarter, to be filed by the 25th of the following month at the latest, with a payment that must be in FPS Finance's account by that date.

Questions about your situation? Your tax coach is here to help via the chat 😊

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 ?