Accounting and invoicing for VAT
I am subject to VAT. What are my accounting obligations ?
As the VAT system is organised around accounting, you, as a person subject to VAT, must comply with a number of obligations. For example, you must keep accounts that are appropriate for the scale of your activities.
In order to be able to apply VAT and make it possible for it to be checked, everything that you record in your accounts must:
- reflect the amount stated in the periodic VAT return;
- be substantiated by an accounting document.
The accounts must contain at least the following books:
- a book for incoming invoices and credit notes;
- a book for outgoing invoices and credit notes;
- a revenue ledger for each place of business (for all transactions with private individuals for which no invoice were issued);
- a centralised ledger if you have several places of business.
You also have to keep a special register for certain transactions:
- the VAT register of motor vehicles;
- the VAT register of non-transfers; this is the register of goods that a person subject to VAT sends or transports to another EU Member State for business purposes with a view to carrying out certain transactions;
- the register of material works or the provision of expertise relating to movable property;
- the reimbursement register.
Under the normal VAT regime, you must comply with all obligations. There are derogations for special regimes (flat-rate, exemption, agriculture) and simplified accounting may be sufficient in some cases.
I am subject to VAT. What are my invoicing obligations ?
There is no invoicing obligation:
- when supplying goods or services to natural persons (irrespective of whether they are subject to VAT) for their private use.
However, the trader can choose to issue an invoice. If an invoice is not issued, an entry must be made in the revenue ledger. This can be done once a day as a total amount, unless the unit price of the goods supplied (including VAT) exceeds EUR 250. In such cases, you must record that specific supply of goods separately.
There is however an invoicing obligation:
- when supplying goods or services to a person subject to VAT or to a legal person not subject to VAT in the context of your profession;
- when distance-selling to a person not subject to VAT;
- where the tax becomes chargeable (on all or part of the price of the transaction) before a supply of goods or services as referred to in the previous paragraphs is made;
- when supplying new means of transport shipped or transported to the purchaser by the seller, by the purchaser or on the behalf of the latter outside Belgium but within the Community;
- in the case of the following supplies (even if the customer is a natural person acting privately):
- the supply of means of transport, irrespective of whether they are new or second-hand, are used for the carriage of passengers or goods or are land vehicles or other means of transport; this also applies to the supply of parts and accessories therefor and to the works carried out on them at a cost of more than EUR 125 (including VAT);
- the supply of new buildings and rights in rem relating thereto;
- works on immovable property;
- the supply of goods and services intended for the construction of a new building;
- the sale of goods on instalment credit terms and hire‑purchase;
- the supply of goods clearly intended for professional use;
- supplies made in establishments or places not normally accessible to private individuals;
- supplies made by producers or wholesalers;
- removals or furniture storage and the associated services;
- certain supplies of goods and services exempt from VAT and made in the context of international relations;
- supplies of investment gold for more than EUR 2 500.
Time of invoicing
The invoice must be issued no later than on the 15th day of the month following the month in which the chargeable event of the transaction took place. This is, in principle, when the tax becomes chargeable, although there are exceptions.
GKS ticket or receipt
Operators of establishments in which food is consumed and providers of catering services must issue a GKS (Geregistreerd Kassasysteem – registered cash register system) ticket for all transactions relating to food and beverages where the turnover relating to restaurant and catering services exceeds EUR 25 000. Below that threshold, they must issue their customers with a numbered bill or receipt printed by an authorised printer. This bill or receipt is also obligatory for car wash operators and for accommodation provided by hotels.
The bill or receipt may be replaced by an invoice, provided that it is issued at the time of completion of the service. An invoice can never replace a GKS ticket.
Retention obligation
You must keep invoices, copies thereof, accounting books and other documents for 10 years. For accounting books, this period starts from 1 January of the year following the year in which they were closed. For invoices and other documents, it starts from 1 January of the year following the date of issue of the documents.