Reimbursement of costs of charging electric and hybrid cars at home - Common sense: the CREG tariff - the saga continues!
Bart Vanham
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A few months ago, I addressed this subject already on this forum. I argued to use common sense and practicality for the reimbursement of home charging cost for electric and hybrid company cars at home. Now finally, the Minister of Finance in Belgium has announced plans to temporarily accept the CREG tariff until technology makes it possible to capture the real cost.
What is it about?
The reimbursement of the electricity for charging a company car at home, just like with a fuel card for a diesel company car, for example, is included in the flat-rate benefit in kind calculated for the company car in question, provided that:
·???????? The charging station is provided by the employer; Here, the answer to the parliamentary question clarifies that the charging station may also be owned by the employee. This provides the necessary flexibility in the context of a change of employer or the employee's own (fiscally interesting) investments in a charging station.
The provision of the charging station by the employer is, once again, also deemed to be included in the flat-rate benefit in kind calculated for the company car
·???????? The charging station must have a specific communication system to indicate how much electricity is consumed. In principle, this is the case with the use of the charge card. It is now indicated that another form of communication is also accepted, insofar as it is verifiable. An intermediate counter indicating the number of KwH consumed by the company car in question is considered possible
·???????? The car policy provides for the reimbursement of the electricity used for the company car in question when charging at home
·???????? The reimbursement by the employer must be made on the basis of the employee's actual electricity costs. For this purpose, all means of proof under ordinary law, with the exception of the oath, are permitted.
And the last point is where the shoe pinches. After all, most companies apply reimbursement on the basis of the CREG rate. The CREG rates depend, among other things, on the region in which you live. This rate is an average market price and changes monthly. Since December 2022, CREG tariffs have been published at the end of the month. In practice, this means that charging sessions of the current month will always be reimbursed at the CREG rate of the month that has just ended. In short, for a larger population, a correct reflection of the actual cost of electricity.
But in practice, this CREG rate can deviate (slightly) from the actual electricity costs (especially for a small population). What are those actual electricity costs? What does the employee actually pay to the supplier? What about solar panels? And batteries? Can I be charged a depreciation fee? Who is going to administer this? Who's going to check this? And many more questions....
Quite a bit of anxiety is projected into the world. No different with this topic. But what are the possibilities?
Common sense:
·???????? The CREG rate is an average rate of the region in which you live
·???????? The CREG rate is an average: sometimes it will be a bit higher than your actual costs, sometimes a bit lower...
·???????? A company usually has several company cars, so an average will substantiate the above point... On average, therefore, the employer does not pay employees more than the average of the actual electricity costs
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·???????? Depending on the exchange rate of the electricity costs, increasing or decreasing, the CREG tariff, which is the basis for the reimbursement one month (or time) later than the consumption, will also be a little less or more than the actual electricity costs. However, over a longer period of time, this will approach the actual cost of electricity
·???????? The employees who have invested in solar panels. Great, that's what the government stimulates; It's great that you put your savings into it to achieve a lower electricity cost. But have you installed those solar panels for your car or your home, or both, which consumption takes precedence? And what investment cost can you charge to calculate the actual electricity cost?
·???????? The Charge Point Operators now have a transparent, administratively clear method of reimbursement of the electricity used for charging the company car at home. Is the responsibility of controlling the actual cost of electricity going to be placed on them? Resulting in more expensive services?
·???????? Will the tax authorities recruit additional staff to carry out these checks?
·???????? If it is not the actual electricity costs, then it is in principle a reimbursement of costs proper to the employer. Many flat-rate regimes have also been created for these costs, e.g. costs for working from home, for the sake of administrative simplification. This must be stated on the payslip, but in principle this reimbursement of costs proper to the employer is not taxable on the part of the employee....
·???????? ....
The above-mentioned list, which can undoubtedly be supplemented (feel free in comments) clearly shows that, unless a technological white rabbit comes out of the hat, there is only one possibility to realize the repayment of electricity used for charging the company car at home in a controllable, transparent, and administratively manageable manner; the use of the CREG tariff.
The Minister of Finance in Belgium has announced plans to temporarily accept the CREG tariff until technology makes it possible to capture the real cost. A royal Decree or Administrative letter will be published soon in this regard..... hopefully common sense will surface to keep the devil from the details....
To be continued.....
Bart Vanham, Fleet360
MVVP | Partner HR Tax, Reward and Compensation & Benefits
1 个月The easiest way will indeed be to accept a lump sum amount every month, like a WFH indemnity. However, the CREG (special !!) rate is “just” the rate to apply. #step1 If tax authorities keep fixated on “actual” electricity (#step2), you still need to have the tools installed at home to measure this actual electricity that went to the EV so the tax authorities can sleep well at night knowing that you are not reimbursed by your employer for using your dishwasher… Also very curious ?? about the solar panel saga… shall tax authorities continue to avoid the sun like vampires traditionally do, or will they embrace the more common sense idea that sun-based electricity has its own “opportunity” cost which can be for example equal to this special CREG rate ?? Fingers crossed tax authorities may pick-up this idea…?
HR | International Employment | BV vrijstelling | Auteursrechten | Rulings | Tax | R&D | Payroll | (Global) Mobility
1 个月Hi Bart I like to believe God is in the details... I trust the administration is aware of all pitfalls and comon sense will surface
Experienced Independent (International) Tax Consultant
1 个月Verhelderend