Your VAT Adviser Cannot Reconcile Invoices That Never Arrive

Dutch VAT control starts where sales invoices leave the founder’s hands and enter the accounts.

The VAT return is almost ready. The adviser asks whether all sales invoices have been supplied. The founder says yes, then remembers two invoices raised through a customer portal and another sent directly from a project system. None appears in the accounting package.

This is a familiar gap between selling, invoicing and reporting. The work happened, the customer was billed and perhaps even paid. Yet the VAT return sees only what reached the administration. By the time a bank receipt raises a question, the relevant return may already have been filed.

Many businesses place too much meaning on the sentence, “My adviser handles the VAT.” An adviser can prepare a return, review bookings and question unusual entries. The adviser cannot reliably account for an invoice that remains in someone else’s inbox, spreadsheet or sales system.

Delegation has a boundary

The Dutch Supreme Court addressed that boundary in its judgment of 19 December 2025, ECLI:NL:HR:2025:1961. A taxpayer who fails to give an adviser the information required for a VAT return cannot simply rely on the return’s correctness.

The wider lesson matters more than the dispute itself. Dutch VAT administration begins inside the company. Under the invoice system, output VAT is generally reported according to invoices issued during the relevant period. The invoice date normally determines that period. Payment arriving later does not shift the original VAT moment, subject to recognised exceptions such as the cash-accounting scheme.

Businesses must retain copies of their sales invoices. The invoice and its accounting entry must remain traceable to each other. That connection lets the founder, adviser and Belastingdienst understand what was sold, when it was invoiced, how VAT was calculated and where it appeared in the return.

The practical question is precise: who confirms that every issued invoice and credit note has entered the administration before the VAT return is approved?

A bank receipt is a late warning

Small businesses often discover missing turnover through the bank. A customer pays an amount that does not match an open debtor. Someone then searches old emails and finds the invoice. The reconciliation has worked, but it has worked late.

A bank feed is useful evidence. It is not a sales-invoice register. It may show that money arrived, but not always which invoice created the payment, which VAT rate applied or whether a credit note followed. It cannot confirm that every invoice reached the adviser before filing.

That modest administrative weakness can affect the whole company. Turnover in commercial life differs from turnover in the accounts. The VAT return understates the tax due. The debtor position becomes unreliable. Cash that includes VAT may be treated as available for wages, suppliers or investment.

When the omission appears, the correction lands in a later cash period. That can be uncomfortable even where everyone acted in good faith. The business may already be carrying slow-paying customers, thinner margins or a large supplier bill. Tax linked to an earlier sale then competes with today’s commitments.

The correction clock matters

Since 1 January 2025, the Belastingdienst states that a business discovering underreported VAT must generally submit a supplementary VAT return within eight weeks. This gives an ordinary reconciliation a sharper governance meaning. The day a discrepancy is found can start a defined correction period.

A sensible response records when the issue was discovered, which invoices are involved and how the proposed correction was assessed. That short record helps management and the adviser work from the same facts. It also prevents an open question from sitting unanswered until the next quarter or year-end review.

Penalty questions require care. A missing invoice does not automatically establish gross negligence or conditional intent. Those findings depend on the facts. The Belastingdienst must explain its reasoning and allow the taxpayer to respond. Still, a business with no handover record, no reconciliation and no clear approval step may struggle to explain why invoiced turnover disappeared from its returns.

This is governance in its smallest useful form. It does not require a committee. It requires one named person to know where invoices are created, one agreed cut-off for delivery to the adviser and one review connecting issued invoices, credit notes, ledger turnover and the VAT return.

Control should follow the sale

Return to the founder facing the filing deadline. The useful response is not another general message asking whether everything is complete. Compare the invoice sequence and credit notes with the sales ledger. Then examine unmatched receipts and unusual customer balances. Any separate portal, spreadsheet or project tool belongs in that review.

The adviser’s role should also be clear. What information is expected? By what date? Who answers exceptions? Who approves the completed return? These simple questions prevent the dangerous assumption that responsibility moved merely because filing work was outsourced.

An invoice is evidence of a sale, a tax event, a customer claim and future cash. When it moves outside the normal process, each of those views can separate. Commercial turnover, the ledger and the VAT return may then tell different stories.

The goal is not flawless administration or distrust of advisers. It is a reliable handover between commercial reality and the return. Before approving the next VAT filing, management should be able to answer one question calmly: does the turnover reported match the invoices we actually issued? If the answer depends on memory, the adviser is already working with too little.

The data, sourcing, and analysis behind this article were conducted by Linda Pavan Geraedts. AI was not used to identify sources, build the factual basis, or produce the analytical judgment contained here. AI was used only as a drafting aid. The final English text was personally reviewed, edited, and approved by Linda Pavan Geraedts before publication.

References

• Geen beroep op adviseur bij ontbrekende btw-facturen - Taxence
• Rechtspraak - Court case: missing sales invoices and reliance on an intermediary
• Belastingdienst - Timing of output VAT under the invoice system
• Belastingdienst - Sales-invoice records and traceability
• Belastingdienst - Retention of records and proof available to the business
• Belastingdienst - Correction of an underreported VAT return
• Belastingdienst - VAT penalties and the distinction between error, gross negligence, and intent
• Rechtspraak - ECLI:NL:HR:2025:1961