Belgian VAT provision account as from 1 May 2026: new guidance clarifies timing of credits and refunds

Apr 27
As from 1 May 2026, the VAT current account will be abolished and replaced by the VAT provision account. The tax authorities have published practical guidance on this change. The guidance clarifies how VAT credits will be managed going forward, when they become available, how they can be reclaimed and which bank accounts must be used.

For businesses that file and pay their VAT returns on time, the basic mechanism does not fundamentally change. The practical impact lies mainly in financial follow-up: payments, credits, offsets and refunds will be organised differently.


VAT provision account becomes the central instrument

As from 1 May 2026, the VAT provision account will replace the former VAT current account.

Amounts available on the VAT provision account will be used automatically to pay VAT due under periodic VAT returns.

The VAT provision account can be funded in two ways. A business can make payments itself, or it can allow VAT credits to be transferred to the VAT provision account by not requesting a refund through the periodic VAT return.

Payments: which bank account should be used?

To fund the VAT provision account and to pay periodic or substitute VAT returns, the following account must be used:
BE41 6792 0036 4210 (TVABTW)

This account applies both to funding the VAT provision account and to paying periodic and substitute VAT returns, as long as the debt has not yet been included in an enforceable title.

The existing structured communication, based on the enterprise number, remains important. Online payment via MyMinfin is recommended, as it reduces the risk of errors: the correct amount, bank account and communication are used.

Until and including 31 December 2026, payments made to the old account will still be automatically redirected to the new account. Amounts paid to the “old” account will therefore not be automatically refunded, unlike the previous situation where payments already made to the “new” account were returned.

For debts that are already further advanced in the recovery phase, a different rule applies. Where a debt has been included in an enforceable title, or where a specific payment notice or reminder is issued, the bank account mentioned in that document must be followed. The guidance refers, among others, to BE42 6792 0000 0054 for certain payment notices.

When do VAT credits become available?

For monthly filers, a credit becomes available in the month following the reporting period. A business that files its June VAT return on time, before 20 July, will see the VAT credit appear on the VAT provision account by 20 August at the latest. That credit can then be used to pay the July VAT return.

For quarterly filers, this takes longer. A credit resulting from the VAT return for the second quarter, filed on time before 25 July, will be placed on the VAT provision account by 25 October at the latest. That credit can then be used for the VAT return for the third quarter.

The message is clear: VAT credits are not necessarily visible immediately, but they can be used for the next VAT return.

 This requires some follow-up.

Late filing: VAT credit cannot be used immediately

Late filing does not only create a risk of penalties. It can also have an important cash flow impact.

Where a monthly VAT return is filed late, a VAT credit is only placed on the VAT provision account two months after the actual filing date. For a late quarterly VAT return, this happens only three months after the actual filing date.

The guidance gives the example of a monthly VAT return for June filed only on 16 August. The VAT credit will then be placed on the VAT provision account by 16 October at the latest. For a quarterly filer, with the same filing date, this would be by 16 November at the latest.

Importantly, in case of late filing, the VAT credit is automatically booked to the VAT provision account, even if a refund was requested in the VAT return.

In addition, a penalty of EUR 100 per month of delay is imposed, capped at EUR 500. In case of non-filing, penalties can range from EUR 500 for a first infringement to EUR 5.000 as from the fourth infringement. The tax authorities may also issue a proposed substitute VAT return, with a minimum VAT amount due of EUR 2.100. The taxable person then has one month to still submit a periodic VAT return.

What in case of late payment?

If the VAT due is not paid on time, late payment interest is due. If payment is not made before the 10th day of the month following the payment deadline, a penalty may also apply.

The penalties are as follows:
  • 5 % where the VAT return was filed on time, but payment is late;
  • 10 % where both the VAT return and the payment are late;
  • 15 % in case of a final substitute VAT return.

Timely funding of the VAT provision account can help avoid penalties, late payment interest and recovery costs. If the balance on the VAT provision account is insufficient, the remaining amount must be paid separately to BE41 6792 0036 4210 (TVABTW), using the correct structured communication.

Refunds: via VAT return or via VAT provision account?

As from 1 May 2026, a clear distinction must be made between two refund procedures.

A refund via the periodic VAT return only relates to the credit resulting from that specific VAT return. Before 1 May 2026, a refund request made through the VAT return could also lead to repayment of the full available balance on the VAT current account. This will no longer be the case.

A refund through the VAT return is requested by ticking the refund request box.

The timing is as follows:
  • monthly filers receive the refund, in principle, at the end of the second month following the reporting period;
  • quarterly filers receive the refund, in principle, at the end of the third month following the reporting period.

A business that wants to reclaim amounts already available on the VAT provision account must submit a separate request via MyMinfin:
My payments
Manage my provisions
Request refund of my provisions

That request can relate to the full available balance or to part of it.

Here too, timing is important. A request made between the 1st and the 15th of the month leads, in principle, to repayment at the end of that month. A request made between the 16th and the 31st leads, in principle, to repayment on the 15th of the following month. The tax authorities do not formulate an explicit reservation in the brochure. This suggests that such payments may be processed automatically.

If there are outstanding debts, the amount requested for refund is first offset against those debts. Only the remaining balance is effectively refunded. If the tax authorities do not have a valid bank account in time, the refund cannot be processed within the normal timeframe.

Transition from the VAT current account

The guidance also clarifies what happens to existing balances on the VAT current account.

Where no refund was requested in the March 2026 VAT return or in the VAT return for the first quarter of 2026, the available amounts on the VAT current account will automatically be transferred to the VAT provision account.

This transfer will take place before 20 May 2026.

For businesses with a significant balance on the VAT current account, this is a practical decision point. They should consider whether they still want to request the credit through the VAT return, or whether they allow it to be transferred to the VAT provision account and reclaim it later via MyMinfin.

Where can everything be monitored?

In practice, MyMinfin becomes the central monitoring point.

Via My payments, businesses can consult outstanding debts and refunds. Via Manage my provisions, they can monitor the VAT provision account and request a refund.

That distinction is important. The VAT provision account shows available provisions and credits, but businesses should also continue to monitor outstanding debts and payment notices.

Cessation of activity

The guidance also covers cessation of activity.

Where an activity ceases before 1 May 2026, a balance on the VAT current account in favour of the taxable person is refunded under the old conditions. If the balance is in favour of the tax authorities, a payment notice is issued.

Where an activity ceases after 1 May 2026, a positive balance on the VAT provision account is refunded after offsetting any outstanding debts. If the business itself requests repayment via the VAT provision account, the refund is processed within one month. Without such request, the refund is made automatically within six months after notification of the cessation.

Conclusion

The introduction of the VAT provision account is more than a change of bank account. It mainly changes the practical follow-up of VAT credits, payments, offsets and refunds.

Businesses would be well advised to review their payment processes before 1 May 2026. Bank details, payment templates, standing orders and similar arrangements should be updated.

For businesses with recurring VAT credits, timing becomes particularly important. A late VAT return does not only lead to penalties, but may also result in VAT credits becoming available only several months later.