In practical terms, the VAT rate for the supply of furnished accommodation and for making camping pitches available will increase from 6% to 12%. The scope of the regime itself remains unchanged: services currently subject to VAT will remain taxable; services currently exempt will remain exempt. Only the rate is amended.
It is noteworthy that the Federal Public Service Finance has already published a FAQ, although the Royal Decree has not yet been officially published in the Belgian Official Gazette. Given the very short implementation period, the administration considers it necessary to inform the sector in advance, albeit subject to formal publication.
A transitional measure has, however, been introduced. For bookings made no later than 28 February 2026, the 6% VAT rate will continue to apply, provided that the VAT becomes chargeable no later than 30 June 2026. The timing of bookings, invoicing and payments will therefore be crucial. For bookings made as from 1 March 2026, the new 12% rate will apply without exception.
The question is therefore not only when a reservation is made, but above all when VAT becomes chargeable. That moment differs depending on whether the customer is a taxable person VAT registered for VAT purposes B2B or a private individual B2C.
The question is therefore not only when a reservation is made, but above all when VAT becomes chargeable. That moment differs depending on whether the customer is a taxable person VAT registered for VAT purposes B2B or a private individual B2C.
In a B2B context, the invoice based system applies in principle where there is an obligation to issue an invoice. VAT becomes chargeable upon issuance of the invoice. If no invoice is issued or if it is issued late, VAT becomes chargeable at the latest on the fifteenth day of the month following the month in which the taxable event occurred. If an advance payment is received before the taxable event, VAT becomes chargeable on that amount upon receipt of the advance payment.
In a B2C context, the payment based system generally applies. VAT becomes chargeable upon payment, irrespective of whether that payment takes place before, on, or after the taxable event. The voluntary issuance of an invoice does not in principle alter this. However, the tax authorities accept that, for unpaid amounts, the invoice date may be followed, provided this approach is applied consistently to all such invoices. In that case, VAT becomes chargeable at the earlier of the payment date or the invoice date. Circular 2019/C/65, paragraph 49.
For operators, this means that pricing and systems will need to be adjusted in the short term. Particular attention should also be paid to the way prices are advertised or confirmed, as well as to the processing of bookings, deposits and invoices, since the applicable VAT rate depends on when VAT becomes chargeable.
The message is clear. Those wishing to remain subject to 6% VAT must carefully observe the transitional regime: booking no later than 28 February 2026 and ensuring that VAT becomes chargeable no later than 30 June 2026. The legislator is evidently allowing little time for adjustment.
Should you wish, we would be pleased to assess what this means in practice for your business.