Invoicing Non-EU Clients from Belgium: VAT and Customs Rules

Invoicing a client based outside the European Union from Belgium involves specific VAT, customs and administrative rules. Whether you sell physical goods to the United States, provide consultancy services to a Swiss company, or export software to the United Kingdom (post-Brexit), this detailed guide explains all the rules you need to follow when invoicing non-EU clients in 2026.

The Basic Principle: VAT Exemption on Exports

Exporting Goods: VAT Exemption (Art. 39 VAT Code)

Article 39 of the Belgian VAT Code provides a VAT exemption for supplies of goods dispatched or transported outside the European Union. This exemption applies whether the client is a business (B2B) or a private individual (B2C), provided the goods actually leave EU territory.

Conditions for the exemption:

• The goods must be physically exported outside the EU
• The export must be proven with customs documents (an EX export declaration)
• The seller must keep proof of export for 7 years

Supplying Services: Place-of-Supply Rules (Art. 21 VAT Code)

For services, the rules differ and depend on the type of service and the client's status:

In short: for B2B services provided to non-EU clients, Belgian VAT generally does not apply. The invoice is issued without VAT, stating "VAT exemption – Article 44 of Directive 2006/112/EC" or "VAT not applicable – Services under Art. 21, §2 of the Belgian VAT Code".

Exporting Goods: Detailed Procedures

Step 1: The Customs Export Declaration

Any export of goods outside the EU worth more than EUR 1,000 or weighing more than 1,000 kg requires an electronic export declaration through the AES (Automated Export System), known in Belgium as PLDA (Paperless Douanes et Accises), run by the General Administration of Customs and Excise (AGD&A).

The steps are:

1. Filing the declaration: via PLDA or through a customs representative (customs agent)
2. Obtaining the MRN (Movement Reference Number): a unique reference number for the export
3. Presenting the goods to customs at the exit office
4. Obtaining the exit visa (Exit Summary Declaration): confirmation that the goods have actually left EU territory

Step 2: Export Documents

Step 3: The Certificate of Origin

Some destination countries require a certificate of origin to benefit from reduced customs duties under trade agreements. The certificate of origin is issued by:

• The Chamber of Commerce and Industry (CCI) of your region (CCI Brussels, CCI Wallonia, Voka in Flanders)
• Online via the eCertificateOrigin platform run by the Federation of Belgian Chambers of Commerce

EORI Numbers

Any business exporting from Belgium must hold an EORI number (Economic Operators Registration and Identification), which is mandatory for any customs operation within the EU. In Belgium, the EORI number generally corresponds to the VAT number prefixed with "BE".

Application: with the AGD&A, via the online form on the FPS Finance website.

Invoicing Services to a Non-EU Client

B2B Services: The Reverse-Charge Mechanism

When you supply services to a business client (VAT-registered or a company) located outside the EU, Belgian VAT doesn't apply. The service is deemed to be supplied where the customer is established (Art. 21, §2 VAT Code).

Wording to include on the invoice:

• "VAT exemption – Service supplied outside the EU – Art. 21, §2 of the Belgian VAT Code"
• The client's VAT or tax identification number (if available)

VAT return: these transactions must be reported in box 47 of the periodic VAT return (transactions not subject to Belgian VAT but which carry a right to deduct).

B2C Services: Important Distinctions

For services provided to private individuals (non-taxable persons) outside the EU, the general rule is that the service is deemed supplied in Belgium (where the supplier is established) and so is subject to Belgian VAT. However, several exceptions exist:

Services deemed supplied where the customer is established (even B2C) – Art. 21, §3, 7 VAT Code:

• Assignments and licences of intellectual property rights
• Advertising services
• Consultancy, engineering and expert services
• Data processing and provision of information
• Banking and financial transactions
• Hiring of movable tangible property (except vehicles)
• Electronically supplied services
• Telecommunications and broadcasting services

For these services, Belgian VAT doesn't apply if the client is established outside the EU, even if they're a private individual.

Focus: Invoicing Non-EU Clients in Specific Countries

United Kingdom (Post-Brexit)

Since Brexit (1 January 2021), the United Kingdom is treated as a third country. The rules are:

Goods:

• VAT exemption on export (Art. 39 VAT Code)
• A customs declaration is mandatory
• The UK client pays customs duties and import VAT in the UK
• The EU-UK Trade and Cooperation Agreement (TCA) provides for zero customs duties on goods originating in the EU (subject to proving origin)

Services:

• The standard B2B/B2C non-EU rules apply
• The UK is no longer part of the VIES system (VAT information exchange)

Note on Northern Ireland: the Northern Ireland Protocol keeps Northern Ireland within the EU single market for goods. Supplies of goods to Northern Ireland are treated as intra-Community supplies.

Switzerland

Switzerland has bilateral agreements with the EU but is not a member:

• Goods: Belgian VAT exemption applies. Switzerland charges import VAT at 8.1% (standard 2026 rate).
• B2B services: Belgian VAT doesn't apply (place of the customer).
• No strict free-trade agreement for industrial goods, but sector-specific agreements exist. Customs duties are possible depending on the product.

United States

• Goods: Belgian VAT exemption applies. US customs duties vary by product (the US Harmonized Tariff Schedule). Watch for additional tariffs imposed amid trade tensions.
• B2B services: Belgian VAT doesn't apply.
• Sales tax: the US has no VAT but does have sales tax, which varies by state (0% to 10.25%). Generally, the US client is liable for it.

Maghreb and African Countries

• Goods: Belgian VAT exemption applies. Watch for each country's specific import rules (import licences, bank domiciliation, etc.).
• Services: standard B2B/B2C non-EU rules apply.
• Payment: favour letters of credit (L/C) to secure payment in certain countries.

Invoicing: Template and Best Practices

Export Invoice Template (Goods)

INVOICE No. 2026-EXP-042
Date: 18 March 2026

FROM:
TechBelgium SRL
Rue de la Science 14, 1000 Brussels, Belgium
CBE/VAT: BE 0456.789.123
EORI: BE0456789123

TO:
SwissTech AG
Bahnhofstrasse 42, 8001 Zurich, Switzerland
Company ID: CHE-123.456.789

DESCRIPTION               QTY    UNIT PRICE   TOTAL
-----------------------------------------------------
Industrial sensor XR-200   50     EUR 120.00    EUR 6,000.00
Calibration kit CK-50      10      EUR 85.00      EUR 850.00
Shipping & packaging        1     EUR 250.00      EUR 250.00
-----------------------------------------------------
TOTAL (excl. VAT)                              EUR 7,100.00

VAT: 0% - Export outside the EU
VAT exemption - Article 39 of the Belgian VAT Code

INCOTERM: DAP Zurich
Payment terms: 30 days net
Bank: ING Belgium - IBAN BE42 3100 1234 5678 - BIC BBRUBEBB

Country of origin: Belgium
HS Code: 9031.80.38

Specific Mandatory Wording

On an export invoice, always add:

1. The VAT exemption wording, with the precise legal reference
2. The Incoterm used (EXW, FCA, FOB, CIF, DAP, DDP, etc.)
3. The HS/CN code (combined nomenclature) of the goods
4. The country of origin of the goods
5. The payment terms (and currency)
6. The net and gross weight of the parcels
7. The number of parcels and the type of packaging

Incoterms 2020: Choosing the Right Terms

The choice of Incoterm determines how responsibilities, costs and risks are shared between seller and buyer:

Recommendation for Belgian SMEs invoicing non-EU clients: the FCA or DAP Incoterm is usually the best fit. Avoid DDP unless you're familiar with the destination country's customs rules.

Reclaiming Input VAT as an Exporter

An essential point: even though you don't charge VAT on your exports, you keep your right to deduct the VAT you paid on your business purchases (Art. 45 VAT Code). Exports are transactions that are exempt with the right to deduct.

This means that:

• You reclaim the VAT on your purchases of raw materials
• You reclaim the VAT on your overheads
• You can obtain a VAT refund if your deductible VAT exceeds the VAT you owe

Refund procedure: the refund is requested via the periodic VAT return by ticking the relevant box. The refund is paid within 3 months at most (Art. 76 VAT Code).

Specific Reporting Obligations

VAT Return

Export transactions must be correctly reported in the periodic VAT return:

Annual Client Listing

Sales to non-EU clients must not appear in the annual listing of VAT-registered clients (which only covers Belgian VAT-registered clients). Nor do they appear in the intra-Community declaration (statement of intra-Community transactions), which only covers intra-EU transactions.

Intrastat

Intrastat declarations (foreign trade statistics) only cover intra-Community trade. Exports outside the EU are covered by the customs declaration, which feeds directly into the foreign trade statistics compiled by the National Bank of Belgium.

International Payment Methods for Non-EU Clients

Payment Options

Credendo: Belgium's Public Credit Insurer

Credendo (formerly ONDD – Office National du Ducroire) is Belgium's public credit insurer. It offers:

• Insurance against the risk of non-payment on exports
• Cover for political risk (war, embargo, expropriation)
• Free country information on political and commercial risks
• Export financing

Website: credendo.com

Currency Fluctuations

If you invoice in foreign currencies (USD, GBP, CHF), you're exposed to exchange-rate risk. Solutions include:

1. Invoicing in EUR: the simplest solution, but not always accepted by the client
2. A currency adjustment clause: include a clause in the contract to adjust the price if the exchange rate moves by more than X%
3. A forward exchange contract: fix the exchange rate in advance with your bank
4. A foreign-currency account: open an account in the client's currency to limit conversions

Export Support in Belgium

Regional Agencies

Belgium has three regional agencies promoting foreign trade:

• Wallonia-Brussels International (WBI) and the Walloon Export and Foreign Investment Agency (AWEX): for Wallonia and Brussels (www.awex.be)
• Flanders Investment & Trade (FIT): for Flanders (www.flandersinvestmentandtrade.com)
• hub.brussels: for the Brussels-Capital Region (www.hub.brussels)

These agencies offer:

• Export grants (for trade fairs, trade missions, market prospecting)
• Economic advisers in Belgian embassies abroad
• Free or subsidised market studies
• Training in international trade

The Federal Department of Foreign Affairs

The FPS Foreign Affairs, Foreign Trade and Development Cooperation coordinates Belgian trade policy and manages the diplomatic network.

Conclusion

Invoicing non-EU clients from Belgium is a major growth opportunity, provided you master the applicable rules. Remember the essentials: exports of goods are exempt from VAT (Art. 39 VAT Code) subject to documentary proof, B2B services to non-EU clients are generally not subject to Belgian VAT (Art. 21, §2 VAT Code), and your right to deduct VAT is preserved.

Invest in good invoicing software capable of handling international transactions, work with a reliable freight forwarder or customs agent, and don't hesitate to use the regional export agencies, which offer valuable, often free, support.

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This article was written by the Espero-Soft team for the blog dedicated to entrepreneurs in Belgium. For personalised advice, consult an international trade expert or a licensed customs agent.