Extra complication with Belgian excise refund during registration plate changes

For the Belgian excise refund, it is crucial that your fleet always matches the transactions stated on the invoices you receive from your suppliers. In certain countries, including Poland, a change in registration can also lead to a change in the vehicle's registration plate. This mainly happens when:

• the new owner is established in a different powiat (administrative region) from the previous owner, or
• a full re-registration must take place for other reasons

In these cases, a new registration number and a new registration certificate are issued. This means that businesses must immediately update their fuel card to the new registration number. If this is not done right away, the refund for fuel purchases made during this period will likely be rejected, because the registration number on the fuel card does not match the official registration number.

It is important to note that in Poland it is not mandatory in all cases to receive a new registration number. When the new owner is established in the same powiat, the existing registration plate can sometimes be retained. Even so, the risk remains significant, since vehicles registered through lease structures are often spread across different regions. If the lease agreement has been paid off and the vehicle becomes the property of the transport company, the registration changes and with that possibly also the registration number.

It is also important to note that when moving from lease to ownership, the Opdracht Tot Tenaamstelling (OTT) must be completed in time and the vehicle must also be marked as "owned" in the Belgian excise declaration. More information can be found in this article.

In practice, this means that for Polish vehicles, and possibly in other countries with similar systems, every change of registration should be checked in advance to see whether a new registration number will be issued, and the fuel card must be updated immediately once this happens.