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.
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.
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).
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:
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.
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.
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.