The new VAT chain: what changes for businesses and how can pitfalls be avoided?

The introduction of the new VAT chain on 1 May 2026 is one of the most significant changes in Belgian VAT practice in recent years. The previous current account system gave businesses limited visibility, while the new VAT chain introduces a centralised approach that offers opportunities but also requires additional attention.

Businesses that regularly build up VAT credits, file late returns or spread payments over time will be particularly affected by the new rules. The key question is: how does the new VAT chain work in practice, and what steps should businesses take to avoid penalties, interest and recovery proceedings?

A new reality: advance funding through the VAT provision account

At the heart of the reform is the VAT provision account, which replaces the former current account. Businesses can now make advance payments into their VAT provision account.

This provision account acts as a kind of digital wallet. Businesses deposit amounts in advance, and the FPS Finance automatically uses those provisions to pay their periodic VAT returns.

Businesses that file and pay on time will notice little difference. However, businesses that fall behind will face new deadlines, automatic offsets and stricter penalties.

Filing and paying on time: the VAT chain then works automatically

For businesses that correctly monitor their returns and payments, the system remains straightforward:

• the VAT return is filed via Intervat;
• the VAT credit is automatically recorded on the provision account;
• the provisions are automatically used to pay future VAT returns.
  

VAT credits become available:

• the following month for monthly filers;
• the following quarter for quarterly filers.

What happens in case of late VAT returns and payments?

A crucial change is that, in the event of late filing, the VAT credit is only recorded on the provision account 2 months after filing for monthly filers, or 3 months after filing for quarterly filers.

For example, if a monthly filer submits the VAT return for July only on 10 August, the credit will only be recorded on 10 October.

This may affect cash flow, especially for businesses that rely on their VAT credits to pay subsequent VAT returns.

Penalties for late filing

In addition to the delayed availability of VAT credits, penalties for late filing will also be applied more strictly.

The tax administration applies a fixed penalty of € 100 per month of delay, capped at € 500. Businesses that fail to file a VAT return altogether risk more severe sanctions. In case of repeated infringements, the penalty may increase up to € 5,000.

Late payment: automatic interest and increasing penalties

Payment monitoring will also become stricter. If a VAT return is not paid in full and on time, the FPS Finance will first send a payment notice stating the outstanding balance and the interest due.

If payment is still not made by the tenth day of the month following the payment deadline, a penalty will be imposed. This penalty amounts to 5% if the VAT return was filed on time, and 10% if the VAT return itself was also filed late.

If payment remains outstanding afterwards, the debt will be included in an enforceable title and recovery proceedings will begin. From that point onwards, payment must also be made to a different bank account, and additional costs may be charged.

New bank account numbers: one for provisions, one for recovery

The reform also introduces a separation between the bank account numbers to be used for VAT payments. Whereas different accounts were previously used alongside each other, the new VAT chain works with two fixed bank accounts, each with its own function.

For provisions and periodic VAT returns, payments must now be made to:

BE41 6792 0036 4210.

This is the account used to fund the VAT provision account and to pay the balance of periodic VAT returns. The tax administration then automatically uses these provisions to settle the VAT due.

However, when a debt is included in an enforceable title, for example after repeated non-payment, payment shifts to another account. From that point onwards, payment must be made to:

BE42 6792 0000 0054.

This bank account number is used exclusively for amounts that are subject to recovery proceedings. Payments made to the wrong account may delay the recovery process and result in additional costs.

Until 31 December 2026, payments that are still made to old bank accounts will automatically be forwarded to the correct account. From 2027 onwards, this transitional measure will cease to apply, making the use of the correct bank account numbers essential.

Refunds: two separate procedures, each with its own rules

One of the most notable changes within the new VAT chain is that refunds will no longer be handled through a single channel. The tax administration now makes a clear distinction between refunds requested through the VAT return and refunds requested through the provision account. These two procedures operate entirely independently.

When a refund is requested through the VAT return, only the credit arising specifically from that return is refunded. The balance on the provision account remains untouched. If a business also wants that balance to be refunded, it must submit a separate request via MyMinfin.

These are two fully separate procedures, each with its own processing deadlines.

For refunds through the provision account, fixed time windows apply.

A request submitted between the first and the fifteenth day of the month results in payment by the end of that same month. If the request is submitted between the sixteenth and the last day of the month, payment will follow on the fifteenth day of the following month.

Businesses that closely manage their liquidity should therefore carefully monitor these deadlines.

Automatic refund upon cessation of activities

When a business ceases its VAT activities after 1 May 2026, the balance of the VAT provision account will be refunded automatically. The tax administration will first offset any outstanding debts, so that only the remaining positive balance is refunded.

Businesses that want faster access to their credits may submit a refund request themselves via MyMinfin. If no action is taken, the FPS Finance will provide for an automatic refund within six months after the official notification of the cessation.

The system therefore offers both flexibility for businesses that need immediate liquidity and certainty for those that take no action.

Practical points of attention for businesses

The renewed VAT chain requires businesses to monitor their VAT administration proactively.

Businesses should regularly check whether their provision account is sufficiently funded, whether all VAT returns have been filed on time and whether VAT credits have been recorded correctly and in due time. This is particularly important where a VAT return was filed late.

Using the correct bank account number is also essential, as payments in the recovery phase must be made to a different account. Finally, businesses should verify whether there are any outstanding debts that could affect automatic offsets.

Good internal organisation and consistent monitoring of these elements help avoid penalties, interest and unnecessary cash flow issues.

Conclusion

The new VAT chain is a more centralised and automated system. At the same time, it leaves less room for late VAT returns and late payments.

Businesses that comply with their obligations on time will notice little change. However, once delays occur, VAT credits are released later and interest and penalties automatically increase.

In addition, the tax administration intervenes more quickly in the event of persistent arrears, which may lead to recovery proceedings being initiated sooner. Careful monitoring of provisions, VAT returns and payments therefore remains essential to avoid unexpected costs and cash flow issues.

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