Companies and self-employed professionals with
a registered office or permanent establishment (PE) in Italy are generally also
required to report their business transactions with foreign customers and
suppliers to the Italian Revenue Agency.
However, the separate quarterly report was
abolished with effect from 1 July 2022. The data is now transmitted
individually for each transaction in XML format via the electronic exchange
system "Sistema di Interscambio" (SdI).
Foreign companies that merely hold a direct VAT
registration in Italy or are represented there by a tax representative are not
subject to the reporting obligation.
Which transactions must be reported?
The reporting obligation generally applies to
all incoming invoices from foreign suppliers and all outgoing invoices to
foreign customers.
Transactions that have already been recorded
via the SdI or by means of a customs document do not have to be reported again.
Also excluded are certain purchases of goods or services that are not taxable
in Italy, provided the amount does not exceed EUR 5,000 per transaction.
Reporting of outgoing invoices to foreign customers
Invoices to foreign customers are prepared in
XML format, in the same way as Italian electronic invoices, and transmitted to
the SdI. The recipient code to be entered is "XXXXXXX".
Transmission must generally take place within
the deadline applicable to the issue of the invoice. For an immediate invoice,
this is usually twelve days from the date on which the transaction is carried
out. For deferred invoices, the relevant specific invoicing deadlines apply.
The invoice must also be sent to the foreign
customer by conventional means (PDF, paper).
Reporting of incoming invoices from foreign suppliers
Foreign suppliers do not usually issue their
invoices via the Italian exchange system. The Italian recipient of the invoice
must therefore transmit the invoice data itself in XML format. Depending on the
transaction, the following document types are used in particular:
- TD17: Services received from a foreign supplier (EU and third countries)
- TD18: Intra-Community acquisition of goods
- TD19: Acquisition of goods already located in Italy from a non-resident supplier (beni già in Italia)
Transmission must generally be made by the 15th
day of the month following receipt of the invoice or the date on which the
transaction is carried out.
In many cases the Italian recipient is liable
to account for VAT under the reverse-charge mechanism. The XML transmission
therefore does not serve reporting purposes alone: it may at the same time
constitute the VAT integration or the self-invoice.
Relationship with the Intrastat return
Transmission via the SdI does not replace any
Intrastat return that may be required. Where goods or services are acquired or
supplied within the European Union, it must therefore be checked separately
whether an Intrastat return must also be filed.
Penalties for late, omitted or incorrect reporting
In the event of an omitted or incorrect
transmission, an administrative penalty of EUR 2 per invoice may generally be
imposed, capped at EUR 400 per month. If the transmission is made within 15
days of the deadline, both the penalty and the cap are halved.