E-invoicing for foreign clients: does the obligation apply?
You regularly invoice clients in the Netherlands, France or another EU country. Do you also need to send them e-invoices via Peppol? Or does the Belgian obligation only apply to domestic clients?
The short version
The Belgian e-invoicing obligation only applies to transactions between two Belgian VAT-registered businesses. If your client does not hold a Belgian VAT number, you are not required to send a Peppol invoice.
For foreign clients, you may therefore continue to send a PDF invoice by e-mail, just as you did before.
But there are nuances
Client has both a Belgian and a foreign VAT number
Some international companies have a permanent establishment or entity in Belgium and are therefore also Belgian VAT-registered. In that case, the obligation does apply to your invoices to that Belgian entity, even if the parent company is based abroad.
Client requests an e-invoice themselves
More and more European countries are introducing their own e-invoicing obligations — the Netherlands, Germany, France and others are working on similar legislation. Your foreign client may ask you to send an e-invoice, even if you are not legally required to do so.
Peppol is a European network, so if you are already connected, you can in principle also invoice foreign clients via Peppol — provided they are also registered on the network.
Intra-Community supplies and exports
For invoices where VAT is reverse-charged to the client (intra-Community supplies) or where a VAT exemption applies (exports outside the EU), the existing rules continue to apply. These invoices do not need to be sent via Peppol.
In summary
- The Belgian e-invoicing obligation only applies to B2B transactions between Belgian VAT-registered businesses
- Foreign clients without a Belgian VAT number: sending a PDF by e-mail remains permitted
- Foreign companies with a Belgian entity: Peppol is required
- Peppol is European — you can also use it for foreign clients who request it
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