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Compliance7 min read

Invoicing a foreign client as a Belgian developer: VAT, reverse charge and the listing everyone forgets

A Belgian developer with a Dutch client, a German agency and a US startup has three different VAT situations on their desk, and none of them involves charging 21%. The invoices are the easy part. The part that generates letters from the administration is the periodic listing that has to agree with them.

The rule that decides everything: where the service is located

For services supplied to a business customer, EU VAT rules place the supply where the customer is established, not where you are. Your development work for a Dutch company is, for VAT purposes, supplied in the Netherlands. Belgium therefore has no VAT to charge on it, and you do not put 21% on the invoice.

This is the general B2B rule, and remote software work sits squarely inside it. Services to private individuals follow different rules, and a handful of service types (land-related work, admission to events, and others) have their own place-of-supply rules regardless of the customer. If your work is plain consultancy or development for a business, the general rule applies.

Client in another EU country

Your customer accounts for the VAT themselves under the reverse charge. Three things have to be true, and all three are your responsibility.

  • The customer has a valid VAT number in their own member state — verify it in the EU VIES database and keep the proof, dated
  • Your invoice shows both VAT numbers and carries no Belgian VAT
  • Your invoice states that the VAT is reverse-charged — “btw verlegd” / “autoliquidation” / “reverse charge”

Then the step that is genuinely easy to miss: these supplies go into the periodic listing of intra-Community services, filed alongside your VAT returns. It is a separate obligation from the VAT return itself, and the administration cross-checks it against what your customer declared on their side. A mismatch is one of the most common triggers for correspondence.

Client outside the EU

A business customer in the United States, the United Kingdom or Switzerland puts the supply outside the EU VAT system entirely. No Belgian VAT, and these supplies do not belong in the intra-Community services listing — that listing is for EU customers only. Putting your US revenue in it is a common and avoidable error. Keep evidence that the customer is a business and established where you say: the contract, their company registration, correspondence.

What you still get to deduct

Charging no VAT on your sales does not stop you deducting the VAT on your purchases. Your laptop, your monitors, your cloud bill, your software subscriptions, your accountant — the input VAT remains deductible, and because you have little or no output VAT to set it against, you will often be in a refund position. That is normal and expected for a developer whose clients are all abroad.

This is also the strongest argument against the small-business VAT exemption for a cross-border freelancer: the exemption gives up those deductions in exchange for simplicity you largely already have when your invoices carry no VAT anyway.

The recurring mistakes

  • Charging 21% to an EU business customer because it “felt safer” — the customer cannot reclaim VAT that should never have been charged
  • Getting the invoice right but never filing the intra-Community services listing
  • Including non-EU clients in that listing
  • Treating a foreign one-person business as a private individual, or the reverse, without checking
  • Invoicing an EU customer who is not VAT-registered as if they were — reverse charge needs a valid number

Frequently asked

Do I charge Belgian VAT to a Dutch or German company?
Normally no. For services to a business customer, the place of supply is the customer’s country, so you invoice without Belgian VAT and state that VAT is reverse-charged. The customer accounts for it locally. Their VAT number must be valid — check VIES.
What is the intra-Community services listing?
A periodic return listing your supplies of services to VAT-registered customers in other EU member states, filed alongside your VAT returns. It is separate from the VAT return itself and is cross-checked against what your customers declare, so it needs to agree with your invoices.
Does a US client go in that listing?
No. The listing covers EU customers only. A supply to a non-EU business falls outside the EU VAT system: no Belgian VAT, and nothing to list. Keep evidence of the customer’s business status and establishment.
Can I still deduct VAT on my hardware if I never charge VAT?
Yes. Supplies that are located abroad still give a right to deduct input VAT in Belgium, so your laptop, software and other business purchases remain deductible. You will frequently be in a VAT refund position, which is normal for an exporter of services.

This article is general information for a one-person company (BV/SRL), not tax advice. Rules and figures change — confirm your situation with your accountant before acting.

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