Transparency in Home Charging Reimbursements - CREG Rates

Written by MobilityPlus | Feb 10, 2025 12:41:31 PM

The recently published Circular 2024/C/77 by the Belgian Federal Public Service for Finance (article in Dutch) clarifies the tax treatment of costs related to home charging of company cars. The circular reaffirms the existing fiscal obligation that reimbursements for home charging sessions must be based on actual costs. This requirement specifically applies to reimbursements for electricity costs incurred by the employee and partially or fully reimbursed by the employer.

However, the circular acknowledges the administrative challenges posed by actual cost calculations. To address this, it introduces a temporary administrative tolerance, allowing employers to use a quarterly rate determined by the CREG (Belgian energy regulator) until December 31, 2025. This provides employers with time to implement systems that comply with the standards for reimbursing actual costs or facilitate the provision of charging infrastructure.

At MobilityPlus, we support all options and offer flexible solutions to help employers choose the approach that best fits their needs.

Meeting Home Charging Reimbursement Regulations

A. Principles

The tax treatment of reimbursements varies based on the type of travel:

Professional travel: Non-taxable, provided costs are demonstrably professional and the reimbursement matches those costs.
Commutes: Taxable benefit unless the reimbursement falls within the tax-free limit of €490 (2025 assessment year).
Private travel: Always taxable as a benefit in kind.

B. Exception for Fleet Electrification

To encourage fleet electrification, the following exception applies:

If an employer provides a charging station with a communication system that records electricity consumption, and the car policy includes reimbursement of these costs, it is fiscally equivalent to a fuel card.
In this case, only one benefit in kind (the company car) is taxed, without additional taxation on electricity reimbursement, provided the reimbursement exclusively relates to charging the company car.

Reimbursement: Actual Costs or Temporary CREG Rate

The circular confirms that home charging reimbursements should, in principle, be based on the employee’s actual electricity costs. Key points include:

1. Actual Costs: The Standard

Conditions:

Reimbursements must reflect the employee’s actual costs, based on their energy contract and recorded consumption.
Evidence is mandatory and can include documents such as energy bills and charging reports.

Challenges:

Calculating actual costs is complex due to variables such as day/night rates, fixed/variable energy contracts, contract changes during the year, capacity tariffs, etc. These factors create significant administrative burdens for both employers and employees.

2. Temporary CREG Rate Simplification

The circular offers a temporary simplification:

A. Employers can use the following fixed maximum rates per kWh for the first quarter of 2025:

Flanders: €0.2822/kWh
Brussels: €0.3294/kWh
Wallonia: €0.3256/kWh

B. Alternatively, employers may opt for a uniform national rate equal to the lowest regional rate (€0.2822/kWh for Q1 2025).

This tolerance applies exclusively to electricity costs incurred between January 1, 2025, and December 31, 2025. From 2026, actual costs will again be the standard.

Actual Costs: Smart Choices with MobilityPlus

At MobilityPlus, we believe a future-proof home charging policy requires a tailored approach. While we support employers in any chosen solution, actual costs remain the best option for companies aiming for transparency, cost savings, and regulatory compliance.

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