Monthly VAT refund for “starters”

Since 1 January 2020, Belgian VAT legislation has permitted an accelerated VAT refund procedure for so-called “starters”. This new measure allows for the granting of a VAT credit refund within one month after submission of the VAT return, whereas this refund generally takes up to three months to six months.

To whom does this procedure apply?

The accelerated VAT refund procedure applies to taxpayers that have recently started economic activities in Belgium and have submitted a VAT identification form less than 24 months ago. Therefore, a taxpayer is considered as a “starter” during the period of 24 months following the start of their economic activities in Belgium. The procedure also applies to existing entities that deactivated their Belgian VAT number at least 3 months ago and that have recommenced their economic activities, which requires a new VAT identification in Belgium. The same applies for newly constituted VAT groups.

This development is also relevant for non-Belgian companies that have been recently identified for VAT purposes in Belgium, even if they were already identified for VAT in Belgium in the past (and provided that such previous VAT identification was cancelled more than 3 months ago). These companies will be considered as a starter during a period of 24 months, which allows for an accelerated VAT refund in Belgium. However, taxpayers who are identified under a global VAT number will never qualify as a starter under this procedure.

Conditions and formalities

To benefit from this procedure, the taxpayer must meet the following conditions and formalities:

• The VAT credit for which a VAT refund is requested should relate to the period of 24 months following the commencement of the economic activities, as stated in the VAT identification form.
• The taxpayer must submit their periodical VAT returns on a monthly basis.
• The monthly VAT credit must at least reach an amount of EUR 245.
• The periodical VAT return must be submitted, at the latest, on the 20th of the month following the month to which the VAT return relates. VAT authorities do not accept any derogations here, such as an extension of the filing deadlines in the summer.
• Periodical VAT returns must be submitted electronically, via the online portal INTERVAT. Again, no derogations are accepted here.
• The taxpayer must, if applicable, explicitly request a refund of the VAT credit in the monthly VAT return, which occurs by ticking the box “request a refund” in the VAT return.

Provided that these conditions and formalities are met by a starter, the monthly VAT refund will be granted automatically. Hence, the taxpayer does not need to request a monthly VAT refund permit nor do they need to notify the Belgian VAT authorities that they would like to apply this procedure