Belgium: the Vat authorities

The Belgian VAT authorities have published a new circular letter on e-invoicing outlining the basic conditions applying to it. The first prerequisite is that this form of invoicing must be accepted by the recipient of the invoice. Secondly the authenticity of origin, the integrity of content and the readability of the invoice should be guaranteed from the issuance of the invoice throughout the complete legal archiving period of 7 years (15 years when related to immovable property).

In particular with regard to the first condition, the authorities emphasize that the right to deduct input VAT could be jeopardized if acceptance of e-invoicing cannot be proven. The authorities therefore recommend drafting a specific agreement on e-invoicing or integrating a provision on e-invoicing into a written agreement.

Whereas in the past, the requirements of authenticity and integrity could only be met through the technology of an electronic signature or EDI (electronic data interchange), the Belgian legislation and administrative practice gradually left the choice of how to cope with these requirements to the business.

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