VAT and small companies: no annual client listing
Companies falling within the scope of the VAT exemption scheme for small companies should until now communicate their annual turnover through the annual client listing. In case you do not have any VAT payers as client, you do not have to file this listing. But what with the annual turnover?
Small companies can be exempt from a number of VAT obligations. Under the exemption scheme you should not e.g. file periodical VAT returns, charge VAT to your clients or pay to the Treasury.
Off course the VAT you have paid on your purchases and investments is not deductible.
There are still some mandatory requirements. You are a VAT payer and therefore you must have a VAT identification number. Additionally, also the obligations on invoices and accounting remain applicable.
This scheme is open for small companies (individuals, companies, ...) with an annual turnover of less than 25.000 euro. But certain companies are excluded from this scheme (such as catering and construction companies).
How do you calculate the 25.000-euro threshold?
The turnover in principle equals the amount, excl. of VAT, of all transactions subject to VAT. But also, a number of exempt transactions should be added such as exports, intracommunity supplies, real estate and financial transactions (except when there are ancillary).
The supply of investment goods and transactions abroad are not taken into consideration.
In order to benefit from the special scheme for small companies you should report this turnover. You should specifically report it on the annual client listing for supplies or services provided during the previous year to VAT payers.
Each VAT payer should file such listing through INTERVAT before 31 March; these SMEs are not excluded from this obligation.
Filing obligation or not?
Each VAT payer should file this listing except ... when you have no VAT payers as clients. A 'nihil' listing should not be filed.
But when you as a small company have such a nihil listing, you should report your turnover on a listing which should not be filed?
A recent royal decree brings clarity: VAT payers under the exemption scheme for small companies which should not file a listing of clients/VAT payers are at the same time no longer obliged to communicate their turnover to the VAT authorities. As simple as can be.