On 12 February 2026, Italy’s Revenue Agency aligned its VAT rules with EU law, allowing special purpose vehicles in merger‑leveraged buyouts to deduct input VAT on transaction costs. Resolution No. 7/2026 confirms these SPVs as VAT‑taxable entities, following Supreme Court rulings in August 2024 that recognised their preparatory role. The change restores VAT neutrality and opens a refund window for historical VAT leakage.
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VatCalc · 11 days ago
Italy has amended its 2026 barter VAT rules, replacing the cost‑based valuation model with a contractual value approach. The change, effective 1 January 2026, requires the taxable amount to reflect the parties’ agreed monetary value but not fall below the supplier’s direct costs, and applies retroactively to contracts from that date while protecting earlier invoices.
StudioLegalEbianucci · 17 days ago
The Court of Cassation’s Order no. 17536/2025 clarifies that formal violations of VAT bookkeeping and invoice preservation do not automatically bar the right to deduction, provided substantive obligations are met. The ruling sets two exceptions—fraudulent intent or inability to prove substantive compliance—under which deduction is denied. It reinforces the principle of fiscal neutrality while maintaining sanctions for formal non‑compliance.
Meridian Global Services · 19 days ago
From 1 January 2026, Italy has enacted a new automated VAT assessment regime for omitted annual returns, allowing the tax authority to calculate VAT due using e‑invoicing and other digital data. The automated determination must be completed by 31 December of the seventh year following the missing return, and penalties are capped at 120% of VAT due, reducible to one‑third if paid within 60 days of notice.
The Invoicing Hub · 20 days ago
Italy’s e‑invoicing system will adopt new SDI technical specifications effective 15 May 2026, adding VAT‑group checks, expanded accreditation limits, and a sports‑worker exemption code. The ViDA directive will require Italy to shift from its centralized SdI model to a decentralized reporting architecture by 1 January 2035, and to adopt the EN16931 standard. These changes affect ERP vendors, e‑invoicing service providers, and all businesses issuing electronic invoices in Italy.
Commercialista Telematico · about 1 month ago
The article examines a case where an Italian company offers a €5,000 discount to a German customer in exchange for advertising services, treating the discount as a VAT swap under Article 11 of DPR 633/1972. It discusses whether the discount should be applied as a reduction on the supply invoice or issued as a separate credit note, and explains the reverse charge mechanism in Italy.
Commercialista Telematico · about 2 months ago
The 2026 Italian Budget Law amended the VAT base for permutative operations, aligning with EU Directive 2006/112/CE. The new rule requires the taxable base to be the normal value of goods and services, defined as the price a transferee would pay in free competition to an independent third party. This change applies to all permutative operations under Italian VAT law.
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Key Takeaways
On 12 February 2026, the agency abandoned its restrictive practice, aligning with the Supreme Court and EU.
It confirms that such SPVs qualify as VAT taxable entities and may deduct input VAT on transaction costs.
Decisions Nos. 22608 and 22649 of August 2024.
By using the refund mechanism under Article 30 ter of Presidential Decree No. 633/1972, supported by robust documentation.
Primary source
Read the full article at Bloomberg LawThis summary was published on VATfaqs.com on 27 February 2026. It relates to VAT developments in Italy. The original source is Bloomberg Law.
