Belgium Transposes First Stage of the EU’s ViDA VAT Package

The Belgian government submitted draft bill DOC 56 1718/001 to the House of Representatives, transposing part of Council Directive (EU) 2025/516 — the "VAT in the Digital Age" (ViDA) package — into the Belgian VAT Code. The bill covers refinements to the existing B2C e-commerce VAT rules and a phase-out of the call-off stock simplification regime.

What is the ViDA package? ‍

ViDA amends the EU VAT Directive (2006/112/EC) around three pillars, as set out in the bill's own explanatory memorandum: (1) electronic invoicing and digital reporting (Articles 1 and 5 of the Directive), (2) single VAT identification and the one-stop-shop system (Articles 2, 3 in part, and 4), and (3) the platform economy (Article 3 in part). Belgium already used the option under Article 1 of the ViDA Directive to introduce mandatory structured e-invoicing between certain taxable persons from 1 January 2026.

What does the draft bill change, and from when?

The bill has two effective dates:

• 1 January 2027 — most provisions, transposing Article 2 of the ViDA Directive: clarifications to the existing B2C distance-selling and OSS rules introduced by Directives 2017/2455 and 2019/1995.

• 1 July 2029 — repeal of two reporting obligations tied to the call-off stock (voorraad op afroep) regime, transposing Article 4 of the Directive.

Two other ViDA pillars — the wider single VAT registration package (Article 3) and e-invoicing/digital reporting (Article 5) — will be transposed separately, applying from 1 July 2028 and 1 July 2030 respectively; those draft bills have not yet been submitted.

What changes for distance sales and the €10,000 OSS threshold?

Under the current rule, intra-EU distance sales of goods (and TBE services — telecommunications, broadcasting, electronically supplied services) are taxed in the supplier's Member State of establishment, rather than the customer's Member State, if the supplier is established in only one Member State and total qualifying cross-border sales stay under €10,000 per year.

The bill clarifies that this €10,000 threshold is calculated only on goods or services sent from the supplier's Member State of establishment to the customer's Member State — not on the supplier's aggregate cross-border sales to all Member States combined. It also introduces an irrebuttable presumption: a supplier who has applied the OSS Union scheme for a given sale is deemed to have opted for destination-based taxation for that flow.

What changes for electronic interfaces (marketplaces, platforms)?

The deemed-supplier rule for electronic interfaces facilitating goods supplied within the EU by non-EU established sellers (Article 13bis of the Belgian VAT Code) is extended. It currently applies only to supplies to non-taxable persons; it will now also cover supplies to taxable persons and non-taxable legal persons whose intra-Community acquisitions are not subject to VAT, as well as any other non-taxable person — aligning the customer categories with those used for distance sales, and covering domestic supplies with no cross-border transport too.

What changes in VAT chargeability under the OSS schemes, and what happens to the voorraad op afroep (call-off stock) regime?

For supplies under the OSS Union or non-Union schemes, Belgium will now apply the EU's base rule instead of its own national derogation: VAT becomes due at the time of the chargeable event, or on receipt of an advance payment, ensuring uniform treatment across Member States.

The call-off stock simplification regime (Article 12ter), which lets a business move its own goods to another Member State without registering for VAT there, is superseded from 1 July 2028 by a new, broader single VAT registration regime. The draft bill closes out the old regime: it will only apply to goods transferred up to 30 June 2028, Article 12ter itself ceases to be in force on 30 June 2029, and the related record-keeping and reporting obligations are formally repealed on 1 July 2029, one day later, once their effects have fully worked through.

Other changes in the bill

• Non-Union OSS scheme: no longer requires the non-EU supplier's customer to be established in a Member State — it is enough that the supply is deemed to take place in a Member State. Registration formalities are also simplified (a single electronic address; website details only where available).

• Import scheme (IOSS): businesses benefiting from the small business VAT exemption are now explicitly excluded from using the import scheme.

• Gas, electricity, heat and cold via networks: temporarily (1 January 2027 to 30 June 2028 only), such supplies to qualifying customers are deemed intra-EU distance sales, letting suppliers use the OSS Union scheme for them ahead of the broader 1 July 2028 extension.

What should businesses do now?

The bill has already received the Council of State's opinion and now moves to parliamentary debate. Businesses using the OSS schemes or call-off stock arrangements with Belgium should start reviewing how the changes affect them well ahead of the effective dates — in particular, the new €10,000 threshold calculation taking effect from 1 January 2027, and the 30 June 2028 cut-off for new call-off stock transfers.

At Marosa by Wolters Kluwer, we remain closely attentive to further developments as this bill progresses through the Belgian parliament, and as the remaining ViDA pillars — platform economy and e-invoicing/digital reporting — are transposed into Belgian law.