Deadlines for submitting VAT returns
The introduction of the VAT Chain brings changes to the submission deadlines for periodic VAT returns:
- Monthly returns must be submitted by the 20th of the following month.
- Quarterly returns must be submitted by the 25th of the month following the quarter.
It has been announced that all tolerances will be eliminated. This means that the VAT return for Q4 2024 must be submitted by January 25, 2025, which is a Saturday. Confusion arose when the administration published the 2025 “VAT calendar” on its website, indicating that the new measures would apply immediately (with strict deadlines).
However, the tax authorities later clarified the following deadlines:
However, the tax authorities later clarified the following deadlines:
- Monthly return for December 2024 and monthly IC listing for December 2024: January 20 (as before).
- Quarterly return Q4/2024 without a refund request and quarterly IC listing Q4/2024: January 27. In this case, the new (extended) submission and payment deadline applies. Additionally, as an administrative tolerance, this deadline is extended to the next working day (since January 25 is a Saturday).
- Quarterly return Q4/2024 with a refund request: no extension applies (submission required by January 25 at the latest).
The new circular letter confirms that the extension for quarterly returns (to the next working day) will not be continued. Starting October 2025, all quarterly returns must be submitted on time (i.e., by the 25th of the following month at the latest). For monthly filers, the extension to the next working day will still apply (even after October 1, 2025).
In 2025, the usual “holiday schedule” remains in place. In the past, the administration published annual tolerances allowing for relaxed submission deadlines for monthly and quarterly returns related to the transactions of June, July, and Q2 of each calendar year (as well as for the monthly and quarterly IC listings of the same periods). These tolerances will also apply in 2025. Discussions are ongoing about the future of the holiday schedule beyond 2025.
Mitigated penalty policy
The most notable aspect of the reform is the stricter penalty policy. The administration will impose penalties from the first day a return or payment is late. This marks a significant shift from the (unpublished) policy previously in effect. Until recently, it was widely known that a return could be submitted by the 10th day of the second month following the reporting period without incurring a penalty. For payments, an (informal) tolerance of a few days applied. These tolerances are now abolished, and penalties will be imposed from the first day of delay.
Penalties for late submissions range from €100 (1 month late) to €500 (5 months late). After that, penalties for non-submission apply, taking into account repeat offenses (within 4 years): €500 (first offense) to €5,000 (4th and subsequent offenses). Particularly striking is the penalty for late payment: 5% (for late payment with timely submission of the periodic return), 10% (for both late payment and late submission), or 15% (in the case of a corrective return).
Several mitigations to this policy have been introduced:
- For penalties for late submission of VAT returns:
- For penalties for late submission of VAT returns:
- Until October 1, 2025, the “old” tolerances will apply. This means no penalty will be imposed if the periodic VAT return is submitted by the 10th day of the second month following the reporting period.
- After October 1, a request for penalty waiver can be submitted for a first offense, provided the return is submitted by the 10th day of the second month following the reporting period.
- The 4-year reference period (for repeated non-submission) will only apply starting January 1, 2025.
- For penalties for late payment:
- A permanent tolerance will apply. No penalty will be imposed for payments received by the 10th day of the second month following the reporting period. This tolerance does not apply if the treasury’s rights are at risk or if factual circumstances suggest the delay was not due to circumstances beyond the taxpayer’s control. Note: this tolerance only applies to late payment penalties. Statutory interest (0.67%) will still be automatically applied.
- General tolerances for submission and payment:
- The extension “to the next working day” applies to quarterly filers until October 1, 2025.
- For monthly filers, the extension “to the next working day” remains the rule (even after October 1, 2025).
- The “holiday schedule” (summer tolerances) remains in effect this year. A solution for future years is under consideration.
Other Changes
Further updates on other changes will follow.