Exempt, mixed or without a number
Only taxed work brings you in, even a little of it.
Two groups that both sound exempt
People call two very different groups not VAT-liable. The first has no VAT number at all: an association without VAT, a holding company that only holds shares. The second has a VAT number but does only work exempt under article 44 of the Belgian VAT code: most doctors, dentists and physiotherapists, much education, insurance brokers, and letting property without VAT. For both groups the Ministry of Finance says the same: no duty to send e-invoices over Peppol, and no duty to receive them either. The full rule is on is Peppol mandatory in Belgium.
The trap is for those who think they belong to the second group but also do some taxed work: a physiotherapy practice selling equipment to businesses, a doctor giving taxed lectures, a landlord letting one space with VAT. That makes you a mixed taxable person, and the duty applies to those taxed invoices to businesses. The same goes for the small business exemption: no VAT charged, still VAT-liable, as do small businesses in Belgium need Peppol explains. A foreign company without a fixed establishment in Belgium is out as well, even with a Belgian VAT number. Associations read do non-profits in Belgium need Peppol.
Find out where you stand
- Check in the Crossroads Bank for Enterprises whether you have a VAT number, and for which activities.
- Exempt work only, or no number: you need nothing, and you do not risk the fines of 1,500, 3,000 and 5,000 euro. Decide whether you want to receive voluntarily.
- Some taxed supplies too: set up sending and receiving for those invoices, like any business. The fines run since April; see the news on the e-invoicing penalties.
- Starting an activity with VAT, such as a webshop or letting with VAT? Set up Peppol the day your VAT number becomes active.
- Tell your suppliers whether you have a Peppol address, so they know how to invoice you.
Whether you already have an address shows in the Peppol check; if you are unsure about your status, ask your accountant.
Why receiving still pays
Not required is not the same as not useful. Your lab, wholesaler and energy supplier send their invoices over Peppol to anyone with a Peppol address, and an e-invoice arrives as structured data: no PDFs in a mailbox, no retyping amounts. Registering voluntarily also counts, says the Ministry, as consent to receive e-invoices.
| At 300 incoming invoices a year | PDF by email | E-invoice over Peppol |
|---|---|---|
| Time per invoice, from opening to booking | 4 minutes | 1 minute |
| Time per year | 20 hours | 5 hours |
| At 50 euro an hour | 1,000 euro | 250 euro |
| A receiving address per year | 0 euro | 0 to 120 euro |
To cut that work further, have incoming invoices processed automatically. How to register is in the guide to Peppol registration; which kind of package fits, in which software for Peppol.
What practices and holdings ask us
My supplier only wants to invoice over Peppol. Must I get an address?
Not if you do exempt work only or have no VAT number: your supplier must then deliver the invoice another way. Getting an address is allowed, and often saves you time.
I invoice a hospital. Must that be an e-invoice?
A hospital can be a public body. For public contracts published after 1 March 2024 from 3,000 euro excluding VAT, the government asks for an e-invoice, apart from the business-to-business rule. Ask the hospital how it wants to receive.
Does the 120 percent deduction apply to a voluntary subscription?
That deduction is meant for costs of meeting the e-invoicing duty, for small businesses and the self-employed. Whether a voluntary subscription counts, your accountant confirms.