From the 2022 tax year onwards, non-profit companies are included in the expanded reporting obligation for costs proper to the employer
The tax authorities wish to gain more insight into reimbursements of costs proper to the employer. For reimbursements paid from 1 January 2022 onwards, the total amount of all reimbursed costs of any kind must be noted on the tax form.
If costs are incurred on behalf of an employer/association, the relevant employee or manager will not be taxed for the reimbursement of these costs. The actual costs incurred may be reimbursed on presentation of supporting documents. Alternatively, reimbursements may be based on a flat rate.
For certain types of costs, the tax authorities have specified their own flat rate (“serious standards”). Associations can choose to reimburse other costs according to a flat rate as well. Generally speaking, the estimated flat rate for such costs should be factual.
Previously, any flat-rate reimbursements of costs proper to the employer had to be justified on the individual reporting forms. For flat-rate reimbursements without appropriate serious standards, there was already an obligation to report the reimbursed amounts.
For flat-rate reimbursements based on serious standards, noting “YES, serious standards” on the tax form sufficed. For reimbursements based on supporting documents, “YES, supporting documents” was sufficient.
This is no longer the case. From the 2022 tax year onwards, there is an expanded reporting obligation and the total amount of all reimbursed costs of any kind must now be noted on the tax form. This applies to all reimbursements of employer-specific costs paid from 1 January 2022 as a general principle.
In summary, the changes to the reporting obligation are as follows:
According to the new reporting obligation, if a teacher buys art supplies for school, for example, reimbursement is based on supporting documents and the amount must be noted on the teacher’s 281.10 pay slip.
To avoid additional administrative duties as much as possible, we advise using a payment card in the association’s name if possible, or at minimum, having the invoice made out to the association.
While the legal provisions refer to ‘all’ variable reimbursements without further distinction, according to the Finance minister, if an employee or manager advances the payment for an invoice made out to their association/employer, these costs need not be noted on the form.
Do you require further information about costs proper to the employer? Please don’t hesitate to contact one of our experts
We base our advice on current legislation, interpretations and legal doctrine. This does not prevent the administration from being able to challenge it or to change existing interpretations.
