Transparency in Home Charging Reimbursements - CREG Rates
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.
Key Distinction in Tax Treatment
1. Provision of Electricity (Direct Supply)
Description: Electricity is invoiced directly to the employer and paid by the employer.
Examples:
- Use of a charging pass for public charging stations.
- Charging at the employer’s premises.
- A separate electricity meter and energy contract in the employer’s name for a home charging station.
Tax Treatment: This provision is included in the flat-rate taxable benefit in kind (BIK) of the company car and does not result in an additional taxable benefit.
2. Reimbursement of Electricity Costs
Description: Electricity is invoiced to and paid by the employee, and the employer reimburses these costs partially or fully.
Tax Treatment: The reimbursement is not included in the flat-rate BIK of the company car. It is treated as a separate taxable benefit unless the exact electricity usage and actual costs can be accurately demonstrated.
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.
Technical Requirements for Reimbursements
To qualify for reimbursement of home charging costs, the circular outlines specific technical requirements for charging stations:
Specifiek communicatiesysteem
The charging station must record exact electricity consumption and share this data with the employer in a verifiable manner. This ensures the reimbursement strictly pertains to the company car's charging.
Certified kWh Meter:
From January 1, 2025, all newly purchased, rented, or leased charging stations or alternatives used for monitoring kWh consumption must include a certified kWh meter with an accuracy margin of 2% (Class B) per the Royal Decree of April 15, 2016.
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.