Peppol deadline: 01-01-2026
00

Avoid fines

Peppol deadline: 01-01-2026
00

Avoid fines

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invoicing buildings

PM
20/01/2026
Question

I usually do odd jobs in apartment buildings, for property managers, so on behalf of the owners’ association.

Buildings do have a KBO number but no vAT number, so is that a Belgian company or how should you describe it? Some buildings are registered via Peppol, many others are not, so it has to be done by email. I read that buildings are not required to use Peppol, but it would be useful…

AI provides a comprehensive answer to your question:

A VME is a legal entity, but not subject to VAT (no vAT number), so invoices must always be issued with VAT to the VME itself (using their KBO number), not via 'reverse charge'. Legally, they are a Belgian entity with a CBE number, and for VAT purposes they function as a private person (not subject to VAT). Peppol is useful but not required; invoices may be sent by email/pDF. 

1. VME is a Belgian legal entity, but not subject to VAT:

  • CBE number (Company number): Yes, a VME must have a CBE number. This is their identification number at the Crossroads Bank for Enterprises (CBE) and must be stated on all official documents (invoices, etc.).

  • No vAT number: Because a VME does not engage in any economic activity that generates turnover, it is not considered to be subject to VAT. It therefore does not apply for a vAT number itself and does not submit periodic vAT declarations. 

2. Invoicing the VME:

  • To whom: You always invoice the VME (the "Association of Co-Owners"), not the property manager personally (unless it concerns his management costs).

  • With or without vAT? You must always invoice with vAT (usually 21% on work on immovable property, unless it can be 6%).

  • No 'reverse charge': The 'reverse charge' rule (where the customer must declare the vAT themselves) is reserved for customers who submit periodic vAT declarations themselves (such as companies subject to VAT). The HOA does not do this. 

  • 3. About Peppol:

    • Not required: VMEs are not required to use Peppol.

    • Handy: It would be administratively easier, but sending pDF invoices by email is perfectly legal and common. 

    • Summary for you:

      • Always ask for the VME's CBE number.

      • Send the invoice to the VME (name + address + CBE number).

      • Invoice with vAT (usually 21%) and state the correct vAT rate on the invoice, in accordance with the rules.

      • You can send the invoice by email; Peppol is an option, not a must.

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You really should try it out for yourself. Even if you don’t have a company number yet, you can already go ahead.

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