VAT listing: a guide

It's one of those annual obligations that VAT taxpayers cannot avoid: by 31 March of each year, you must provide the tax authorities with a list of your customers from the past fiscal year. What exactly do you need to do? We'll explain everything to you in detail!

VAT: the obligations to be met

VAT probably has no more secrets for you! When you started your own business, you had to activate your VAT number: two letters (BE) and ten digits that will henceforth appear on all your documents. Since then, that 'value-added tax' has haunted you everywhere: you invoice it to your customers at 21% (or in some cases at 12 or 6%) and then pass it on to the state. You can also deduct VAT on purchases of goods or services paid for by your business. You must keep careful records of all those transactions in your periodic returns (monthly or quarterly). In doing so, you must take into account the many intricacies of this tax matter (such as exemptions and deductions).

So you must follow the pace of the VAT calendar closely. But what about your VAT listing? VAT listing is an obligation that is regularly lost sight of. And that can sometimes have some major consequences! Start-ups – or even experienced entrepreneurs – can often begin to make a mess with this annual tax requirement. You are so busy with your activity and many administrative tasks that you miss the 31 March deadline and simply forget to file the list of your VAT-paying customers. An oversight that can quickly cost you up to a 3,000-euro fine!

Therefore, this first tip: mark 31 March in your calendar and make sure you get a notification of this every year. Especially if an accountant is not assisting you. You won't forget the date now. But actually, what's it really about?

What is the VAT listing? 

The VAT listing is a 'simple' overview of your VAT-paying customers during a fiscal year. In other words, this list contains all the customers with a Belgian VAT number to whom you have supplied goods or services in the past fiscal year. 

In the list, you must report the following for each customer:

• the customer's name;
• their Belgian VAT number;
• the total amount of deliveries and services invoiced;
• the total amount of VAT.

Do I need to declare all my customers? 

No, some customers do not need to be included in your VAT listing:

• customers whose invoiced amount (excluding VAT) does not exceed 250 euros for the whole year;
• customers who exclusively perform transactions exempt from value-added tax (Article 44 of the VAT Code). These include doctors, dentists and physical therapists, as well as health insurance funds, agencies offering family assistance or schools, and a range of specific actions. The full list can be found on the FPS Finance website;
• individuals, because they do not have a VAT number;
• foreign companies, which also do not have a Belgian VAT number.

How do you file your listing? 

You must file your listing through the web platform 'Intervat', unless you always file your periodic returns on paper. Is that the case? If so, you may choose to file a hard copy list with the Scanning Centre. In that case, do not forget to request a form in advance from the competent tax office. Given the current situation, the electronic method obviously seems to be the most efficient ...

Intervat : four steps

1. The first step is to sign up. This can be done through various methods, such as your identity card, a valid residence permit, European electronic identification or the itsme application.
2. Then you have a choice, as the administration has developed an Excel file that makes it easier to aggregate the information. An interesting tool, but you are not obliged to use it. Alternatively, you can navigate further to Intervat's pages and enter the information requested there step by step. This is a fairly simple method if you only need to enter a few clients. For a longer customer list, the Excel file is the easiest solution.
3. Despite its simple formatting and somewhat 'retro' design, Intervat is quite well put together. Before you finally file the listing, the application even does a series of checks (VAT number of your customers, agreement of the amount, etc.) to make sure your data is correct.
4. Final step: you must sign the VAT listing and will be given the option (highly recommended!) to download a copy of your listing.

A zero-customer listing

Is your list empty for some reason (see above)? Then you should file a declaration on Intervat anyway. More specifically, you should enter as amount 0.00 in the boxes for the total amount of turnover and VAT. Once you have entered that information, go to the next step to validate and file your listing.

Watch out for penalities? 

Did you forget to file your VAT listing? Or did you do it too late? Then the FPS Finance can fine you up to 3,000 euros. However, the new penalty policy is a lot more lenient than before and the amounts are now somewhat lower (depending on the type of infraction, repetition, etc.). But really, it makes no difference whether you have to pay 250, 500 or 3,000 euros. No fine is still better!

Exempt from listing? That can happen !

Once your business is subject to VAT, you cannot get away from this annual obligation. That is simply the rule. But, as is so often the case, there are some exceptions. You do not need to file an annual client list in certain specific situations.

This is so in the following cases:

• Your company exclusively performs transactions exempt from value-added tax, in accordance with the well-known Article 44 of the VAT Code. For example, doctors, dentists or physical therapists.
• Your listing is blank, either because you made no transactions or because your customers are all exceptions (see above). However, you are not automatically exempt from the obligation to file your listing: you must still check the appropriate box in your last VAT return for the past year (the one for the fourth quarter or the month of December). If you forget to check that box, you must file a zero-customer listing (see above).
• You fall under the VAT exemption scheme – less than 25,000 euros in turnover per year – for small businesses (as a natural person or company) AND your list is blank, either because none of your customers has a Belgian VAT number, or because your turnover per VAT-paying customer is lower than 250 euros (excluding VAT). If you do not meet these two conditions, you do need to file a VAT listing!

Mixed or partial taxpayer?

We would like to bring this special status to your attention.

• Is your company a mixed taxpayer? That means some of your transactions are subject to value-added tax, while others are exempt. An example of this is a non-profit organisation that directs plays or manages a library (two exempt activities under Article 44 mentioned above), but at the same time runs a cafeteria (subject to VAT). A real estate office can also be a mixed taxpayer if it sells both new (subject to VAT) and old buildings (exempt).
• And what are partial taxpayers, then? There is only a subtle difference between mixed and partial status. Partial taxpayers are businesses or associations with certain transactions that fall within the scope of VAT and others outside it. In other words, the entity is simply not subject to VAT for some of its activities.

Conclusion 

In short, you must mark a dot on 31 March in your calendar to file your mandatory return through Intervat on time. Unless you cease your activities: in that case, you lose your status as a VAT taxpayer and must file your VAT listing within three months from that date.

Technical problems with Intervat? Please contact the tax administration at info.intervat@minfin.fed.be.