Reclaiming VAT from Belgium: what is different per refund country?
When reclaiming VAT from Belgium for the first time, many people assume that the rules are the same throughout the EU. This is only partially correct. Directive 2008/9 governs the process: a single digital request, submitted via the Dutch Tax Authority, which is forwarded to the country where the VAT was paid. However, what that country subsequently allows as a deduction varies by refund country — and Belgium makes its own choices in this regard.
In practice, this means that the same receipt, for example for a business dinner or a rental car, can lead to a different outcome in Belgium than in Germany or France. Not because the directive prescribes it, but because each EU country determines within that directive which cost categories are fully, partially or not at all eligible for refund.
Why countries differ in this
The directive shapes the process, not the content. Each EU country may determine within its own VAT legislation that certain costs are excluded from deduction, even for foreign applicants. This is not a circumvention of the directive, but a competence that is explicitly laid down in it. The result is that the refund country, not the Netherlands, ultimately determines whether a cost item is granted.
The Tax Authority maintains a so-called Requirements List for each refund country, which states what a country does and does not accept and which additional documents the country requires for it. That list is structured differently for each country and is updated periodically by the countries themselves. Anyone preparing a request for multiple countries at the same time should consult that list separately for each country rather than assuming that what works in one country will also work in another.
What this means for a request from Belgium
For Belgium, as for any other refund country, certain cost categories are subject to specific conditions. Representation costs, restaurant visits and costs related to private motor vehicles are categories where countries differ most among themselves — one country allows full deduction, another limits it or excludes a category altogether. For a precise and up-to-date breakdown per cost category, the source is always the official Requirements List of the refund country itself, not a general impression from another file.
This makes it difficult to make an estimate for another country based on experience with one country. An accountant accustomed to German requests may therefore be surprised by a Belgian request, and vice versa. This is one of the reasons why bundling requests for multiple countries is more than just filling in the same form ten times.
Documentation: that is not uniform either
In addition to what is deductible, the strictness with which a country reviews supporting documents also differs. Some refund countries routinely request a copy of the invoice for higher amounts, while other countries only do this on a spot-check basis. The requirements for the legibility and completeness of a receipt can also vary slightly from country to country. Anyone who discovers this only after a request has already been submitted loses time within the window in which the refund country may request additional information.
This is precisely why it is useful to know per refund country what to expect before you submit, rather than afterwards. On the explanation per situation and per country it is clearly set out what is relevant for different types of costs and countries.
Why this matters when bundling requests
Entrepreneurs who incur business expenses across multiple EU member states — refuelling in Germany, staying overnight in Belgium, attending a trade fair in France — typically submit multiple separate applications, one per refund jurisdiction. Each application is assessed against the rules of that particular country. This is also why automation delivers more than just time savings here: receipts must not only be collected, but correctly assigned to the expense category that the refund jurisdiction uses, before an application is bundled and submitted.
Would you like to first get an impression of what this means for your own situation, without having to look up all the country-specific rules immediately? With a few questions you'll see an indication in euros of what you're currently missing out on. How your information is subsequently processed and assessed per refund jurisdiction is explained on the page about how the process works.
Despite these country-specific differences, it remains fundamentally a matter of precisely following what each refund jurisdiction prescribes. Anyone in doubt about a specific cost item or borderline case would be well advised to consult a VAT specialist; this article describes the system, not the outcome of an individual case.
Sort it out yourself or have it sorted out
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