On April 1, 2022, an adaptation of the VAT legislation, Circular 2021/C/96, will come into force.

This circular deals with the scope of the VAT exemption provided for in article 41, § 1, first paragraph, 3° of the Belgian VAT Code with respect to transport services directly linked to the export of goods from Belgium or from another Member State to outside the Community.

The Circular defines the new scope of the exemption as a result of judgment ‘L.C. IK, case C-288/16, of 29.06.2017

This exemption for transport services is directly related to exporting goods from BE or another Member State outside the EU. The adaptation of the VAT legislation only applies in the relationship of the service provider and the consignor or consignee of the goods to be exported.

Impact for you as a DHL Express customer

As of April 1, 2022, all carriers must be able to demonstrate in what capacity you are having transport services performed with us. This applies to all exports of goods to third countries. If you do not let us know this correctly, you may pay unnecessary VAT.

This may include:

  • Always as a sender or addressee (then you are always exempt from VAT)
  • Never as a sender or addressee (then you are always taxed with VAT)
  • Both as a sender/addressee and in any other capacity (*)
  • Both as a sender/addressee and in any other capacity without the possibility of making a distinction (in which case you will always be taxed with VAT)

(*) If you order both transport services in as a consignor and in another form (e.g. as a main carrier for a customer), in the future we would create a second export customer number for you in addition to the existing one: the existing export customer number for services you request as a consignor and a new export customer number for other services.

We need your input

We ask you to confirm under what heading you have transport services provided by us for the export of goods to third countries. And this before 15 March 2022. Make sure that the confirmation is given by an internally authorized staff member.

Attention! We need a written confirmation that you always act as consignor or consignee. Only then can we continue to guarantee tax-free export transport to the third country. Without proof of this, we must assume that all shipments to third countries are subject to VAT.

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