Belgium VAT on warehousing services

The Belgian tax authorities have changed the place of supply rules, and hence the liability to Belgian VAT, for the provision of warehousing facilities to non-resident traders.

Previously, the place of supply rules for storage facilities followed the General Rules.  For non-residents customers, this meant the leasing to non-residents was VAT exempt under the reverse charge rules.  From June 2014 this has now changed.  There are two situations under the new rules:

1. Where the facilities are provided for the exclusive use of the foreign trader, then this is now considered a supply of immovable property, and so the place of supply is Belgium.  Belgian VAT at 21% is therefore applicable.
2. Where other traders may rent the facilities too so that the foreign trader does not have exclusive access, then the General Rule still applies.