Large VAT Groups: new statistical reporting obligations to be taken into account

From 2020, additional statistical reporting obligations apply to members of a large VAT Group (which is being defined as a company with an annual turnover of at least 15 million EUR reported in VAT returns).

A breakdown of information contained in the VAT Group’s VAT return will have to be reported at legal entity level to the National Bank of Belgium (NBB) to allow more accurate statistical accounts (Royal Decree of 11 December 2019).

The first declaration through Onegate, the NBB’s electronic portal, is due by April 20th 2020 for first quarter figures.

What information has to be reported?

Each member of a Belgian VAT Group with an annual turnover of at least 15 million EUR will have to provide the NBB with a quarterly summary of certain figures reported on its behalf in the group’s VAT return:

  • for outgoing transactions: all VAT return data for box 00 until box 49, per box
  • for incoming transactions: the figures reported in boxes 81, 82 and 83 of the VAT return, per box

Practical implementation

The information needs to be reported on a quarterly basis, from the first quarter of 2020, and subsequently the 20th day following each quarter at the latest.

The VAT group representative can file the information on behalf of Members (optional). However, each individual member remains responsible for the reporting.

Please note that:

  • this new reporting obligation applies in addition to the VAT reporting obligations that should be performed by the representative member (VAT return at group level) or the individual members (European sales listing, annual client listing);
  • statistical reporting is often already required from VAT Groups, whereby a breakdown per member of the VAT return details should be provided. However, this has so far only been upon individual request from the NBB and on an annual basis, rather than a general obligation. In addition, previous reporting requests focused purely on cross border incoming and outgoing transactions, whereas the information to be reported as of 2020 has a different scope, which is broader for outgoing transactions but provides less detail on incoming transactions.