If you operate under a Belgian VAT exemption or a special VAT regime, you must include the legal notice for it on your invoice. For a number of these regimes, Lucy doesn't have a separate VAT rate. This page explains why that's the case and how to still get the notice correctly onto your e-invoice.
Here you'll find an overview of all VAT exemptions for which a code is provided in Lucy.
TABLE OF CONTENTS
- Why there is no separate VAT rate
- VAT exemptions without their own VAT rate
- What will change in the future?
Why there is no separate VAT rate
The VAT categories and exemption reasons on an e-invoice come from European code lists. These lists aren't complete for Belgium. Today, there's no code for the small business exemption scheme, for the VAT margin scheme, or for recovered materials. Belgium is working within the EU on an extension with Belgian codes. That extension isn't finished yet.
The FPS Finance has set out an interim solution for this. You use the regular exemption rate and add the legal notice yourself as free text on the invoice. That text is included in the e-invoice, so your customer and the tax authorities actually see it.
- Select the VAT rate "Exempt from VAT" (0%) on the invoice line.
- Add the legal notice in the free note field at the bottom of your invoice. For the notices below, you type the text yourself.
VAT exemptions without their own VAT rate
Small businesses
If you fall under the small business exemption scheme, you don't charge VAT. You put the following notice on every invoice:
Special exemption scheme for small businesses (Art. 56bis of the VAT Code)
VAT margin scheme (second-hand goods, art, collectors' items, travel agencies)
Under the margin scheme, you calculate VAT on your profit margin rather than on the full selling price. That's why no VAT may appear on the invoice. This way, your customer won't mistakenly think they can deduct that VAT.
So the VAT on your margin doesn't run through the invoice. You calculate and keep that separately for your VAT return.
Invoice the full sales value with the "Exempt from VAT" rate and put the following notice on your invoice:
Supply subject to the special profit margin taxation scheme. VAT not deductible.
In the code list, you may see codes that mention the margin scheme. Those only apply to intra-Community acquisitions, not to a domestic sale.
Recovered materials
For recovered materials, VAT isn't due, based on an administrative tolerance. No statutory zero rate applies. You therefore use the "Exempt from VAT" rate and put the following notice on your invoice:
Recovered materials. VAT not applied. Circular letters of 15 December 1970, No. 88, and of 30 July 1971, No. 120.
Reverse charge (within Belgium)
For reverse charge within Belgium, you don't use "Exempt from VAT", but the separate co-contractor rate.
Other situations with the same approach
| Situation | Invoice notice |
| Tobacco products, VAT paid via tax stamps Tobacco products | VAT paid at source and not deductible |
| Advances recharged on behalf of third parties | Advances recharged (Art. 28, 5° VAT Code) |
What will change in the future?
The European e-invoicing standard is being revised. This will introduce separate VAT categories for national schemes and for margin schemes. In parallel, Belgium is working on a list of Belgian exemption codes. Once these become available, you'll be able to select the correct code directly, and the notice will no longer need to be entered as free text. The effective date has not yet been determined.
The exact wording of your legal notice remains your responsibility or that of your accountant. Lucy provides the field where the text is entered and ensures it's correctly included in the e-invoice.