The basic principle
In Belgium, services are taxed at 21% VAT by default. However, the VAT Code provides for specific exemptions. Article 44 §2 4° exempts certain training activities — but the conditions are strict and often misunderstood.
The exemption under Article 44 §2 4° of the VAT Code
The following are exempt from VAT: education and vocational training provided by:
- Recognised educational institutions (universities, colleges, etc.)
- Training organisations recognised by the competent community authorities (IFAPME, Bruxelles Formation, VDAB, etc.)
- Independent trainers exempt from VAT based on an individual authorisation from the FPS Finance
The key: official recognition. Without accreditation, no exemption.
The crucial distinction: accredited training vs coaching
| Criterion | Accredited training (0%) | Coaching (21%) |
|---|---|---|
| VAT applicable | 0% (exempt) | 21% |
| Recognition required | Yes, FPS Finance or accredited body | No |
| Objective | Professional skills acquisition | Personal development, leadership |
| Structure | Defined programme, teaching materials | Conversations, individual follow-up |
| Certificate/attestation | Yes, generally | Not required |
The risk if you misapply the exemption
If you invoice coaching without VAT when you do not qualify for the exemption, you are in tax violation. The tax authority can reassess up to 5 years back and claim the uncollected VAT, plus surcharges (up to 200%) and late payment interest.
Ledgerly handles both rates
In Ledgerly, you configure your products/services with the appropriate VAT rate. Ledgerly applies 0% for exempt training and 21% for coaching, and generates the appropriate legal notices on each invoice.