The tax authorities have published a notice on their website granting an extension to mixed (and partial) VAT taxpayers for reporting their figures. The question is whether the tolerance, as currently presented, actually helps businesses move forward.
Since 2023, mixed and partially VAT-liable taxpayers must report key figures related to their VAT deduction electronically via InterVAT. For partial VAT payers, a tolerance has been provided (so that only large enterprises remain subject to this obligation). Mixed VAT payers are in any case obliged to report their figures in this way, regardless of their size.
For mixed VAT taxable persons applying a general pro rata, the process is relatively straightforward: they only need to input their pro rata percentage.
For those applying the method of actual use, however, there is more work involved: they must calculate the VAT they have deducted (or not) and express in percentages how the right to deduct was determined. This required considerable work last year, which led the former Minister of Finance to decide that estimates would suffice. The issue was that VAT on expenses was not separately recorded in the accounting systems prior to the introduction of the new obligation. It wasn’t until mid-2024 that most accounting software was updated to handle this.
It is therefore somewhat surprising that these issues were not taken into account in the provided tolerances. Only a postponement of the obligation has been granted.
Normally, the figures had to be submitted by 20 or 25 April. These deadlines have now been pushed back to the final submission date of the periodic VAT return for:
Normally, the figures had to be submitted by 20 or 25 April. These deadlines have now been pushed back to the final submission date of the periodic VAT return for:
• the second quarter of 2025 (by 25 July 2025 at the latest), or
• June 2025 (by 22 July 2025 at the latest).
Due to the extension granted during the summer holidays, the deadline is further extended to 8 August 2025 (for both monthly and quarterly filers). In order to benefit from a refund, however, the return must still be submitted within the legal deadline.
This does not change the fact that apparently, this year, “actual figures” must be used (even though most accounting software had not yet been adapted in 2024 – see above).
Taxpayers who wish to do so can initially work with estimates and subsequently submit their actual figures with the VAT return for the third quarter or for the month of November. This essentially results in double work.
We are hearing from various sources that the tax authorities themselves are unsure what to do with the figures reported in 2024. Perhaps it is time to reconsider this obligation?
The tolerance can be consulted here.