Refund or Correction - What Belgian Businesses and POS Providers Need to Know Under GKS 2.0

Belgium’s Cash register system 2.0 (GKS 2.0) FAQ published by Tax Authority clarifies that refunds, corrections and other negative transactions cannot all be treated in the same way. Affected businesses must distinguish the reason for the adjustment because each situation has a different fiscal treatment and reporting consequence. 

TA has further clarified how negative transactions should be treated under the GKS 2.0 registered cash register system framework. For retailers and HoReCa businesses using GKS 2.0, the main point is that a customer refund, an internal correction, a voucher-related adjustment and a product substitution do not represent the same type of fiscal event.

To make it clear on how to record negative transaction, we must first understand when should a Refund be used and what does it represent in Belgian GKS 2.0 system?

A Refund applies where a customer returns goods or where a transaction is cancelled after the VAT (fiscal) Receipt has already been issued. At that stage, the original transaction has already been completed and recorded through the certified cash register system.

For example, if a customer pays, receives a fiscal receipt and later returns the goods or receives a full or partial reimbursement, the subsequent negative transaction should be treated as a Refund rather than as a correction.

No matter if the new Refund receipt represents a full refund of an earlier fiscal receipt, the reference to the original fiscal document must be included. This creates a direct connection between the original sale and the later refund.

For retailers, this means that the return process should preserve the relationship with the original transaction. A refund should not appear as an unrelated negative sale if it actually reverses an already completed transaction.

On the other hand, based on the Tax Authorities’ direct answers inside the FAQ, when does Correction apply? A Correction applies to a different case, as it is to be used when a cashier (employee operating GKS 2.0 and registering payments) corrects an internal input error before final payment and before the transaction has been completed.

A typical example would be a product entered twice by mistake, an incorrect quantity, or another input mistake in entering transaction data becomes identified while the transaction is still open. In that situation, seller is not reversing a completed sale but the employee is correcting an error before the customer completes payment.

This creates a relatively clear legal distinction to follow:

• ­        Completed transaction followed by a return or cancellation should be recorded using a refund option.
• ­        Error corrected before the transaction is completed (i.e. during transaction itself) requires using a correction.

For GKS users, two actions may look similar on the screen because both can result in an item or amount being removed and both are supported by new solutions. Under GKS 2.0, however, the underlying reason is different and should therefore be treated differently by the POS system.

Some situations require a more specific reason, and should be taken into consideration when applying these operations. This is where the FAQ also makes it clear that companies operating GKS 2.0 cannot use the general Correction category for every negative transaction.

E.g.  voucher must be used where the negative line relates to the use of a single-purpose voucher (SPV). Likewise, PRODUCT_SUBSTITUTION applies where one component of a combined or composite product is replaced with another. In these cases, the generic Correction reason should not be used instead.  

From a legal and compliance perspective, this requirement is about maintaining an accurate Audit Trail primarily. The fiscal data should show what actually happened in pracice during the transaction rather than merely recording that the transaction total was reduced.

This is especially relevant in restaurants and other HoReCa environments where adjustments happen frequently. E.g. a waiter may remove an incorrectly entered item, a customer may return an item after payment, a voucher may be redeemed, or one product may be substituted for another. Each of these actions can reduce the value of a transaction, but they do not have the same fiscal meaning and consequence.

Why does this matter for POS configuration in GKS 2.0?

The practical impact for POS providers is that the system should distinguish the relevant retail process before sending the transaction data to the GKS 2.0 online environment. The same principle applies to vouchers and product substitutions. Where the Belgian rules provide a specific category, the POS should not simply map every reduction to a general correction function.

For sellers operating GKS 2.0 - this is also a staff-procedure issue. If employees use the wrong POS function for a return or correction, the fiscal data may no longer reflect the actual transaction process even where the final amount charged to the customer is mathematically correct.

A “return after payment” function, for example, should lead to Refund treatment, while removing an incorrectly entered item from an open transaction (e.g. ongoing transaction that is not finalized) should be treated as correction (also called void of actual receipt).

The impact on affected businesses inside HoReCa and POS providers goes in multiple ways:

For businesses operating under GKS 2.0, return and correction procedures should be reviewed as part of the transition to the new system.

Businesses operating cash register system solutions should check that employees use the correct POS process depending on whether the original transaction is still open or has already been completed.

POS providers should map common retail actions to the corresponding GKS 2.0 treatment and avoid using one generic “negative transaction” function for materially different scenarios that should not be mixed up.

Retailers using or preparing to migrate to GKS 2.0 should review their return, cancellation and correction processes and confirm that they distinguish events occurring before and after final payment. They should also check whether voucher use and product substitutions are handled separately where the actual rules require a dedicated reason.

From our perspective, the practical issue is actually not the technical name of the field used by GKS 2.0, but the fact that Belgium now expects the reason behind a negative transaction to be identifiable in the fiscal record as well, and to bare in mind the specific cases and reasons for using each of the options.

The main source is the official FPS Finance GKS-SCE 2.0 FAQ, particularly questions 301–303, which explain the difference between refund and correction, and the use of specific reasons for vouchers and product substitutions as well.

The FAQ is published within the official Belgian GKS 2.0 framework and should be read together with the applicable GKS legislation and technical documentation available through the official GKS portal: Belgium GKS 2.0 official portal. Direct link to read the full FAQ is available at: https://www.geregistreerdkassasysteem.be/sites/default/files/FAQ%20NL.pdf 

Tara Nedeljković, Team Lead of Legal Consultants at Fiscal Solutions

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