With effect July 1, 2022, there will be key several mandatory changes to the Italian VAT e-invoicing regime. The major changes include:
- Cross-border Esterometro reporting replaced by e-reporting through SDI
- Mandatory e-invoicing between Italy and San Marino
- Extension of the mandatory SDI e-invoicing requirement to small businesses
Cross-border Estermoetro reporting replaced by SDI e-reporting
Since 2019, Italian businesses have had to report sales and purchase invoices to or from foreign businesses to the Italian Tax Authority (Agenzia delle Entrate) on a quarterly basis via the Esterometro report. This includes intra-community acquisitions, imports and exports. The Estermetro reporting obligation was designed to cover invoices that did not fall under the scope of SDI e-invoiding mandate. However, from July 1, 2022, the data relating to cross-border transactions must instead be transmitted to the Italian Tax Authority via the national e-invoicing platform, Sistema di Interscambio (SDI) in a mandated XML format (FatturaPA version 1.6.1 that is currently used for e-invoicing in Italy). The reporting deadlines for this new requirement are:
- Sales invoices within 12 days of time of supply
- Purchase invoices by the 15th of the month following the time of supply.
While mandatory e-invoicing will continue to only apply to domestic invoicing and there will be no requirement to physically issue or receive e-invoices to or from non-resident customers and suppliers, there will instead be a requirement to e-report relevant invoice data via the SDI e-invoicing platform.
Some key technical points of the e-reporting via SDI for business to consider include:
- Cross-border invoices will continue to use the standard SDI document types (TipoDocumento) e.g
Type
| Code
|
Invoices
| TD01
|
Credit Notes
| TD04
|
On the basis that non-resident businesses do not have an SDI receipt code (Codice Destinatario), “XXXXXXX” should instead be used for the field.
Where the relevant country’s postal code/ZIP code (Codice di Avviamento Postale - CAP) does not meet the Italian five digit format, “00000” should instead be used in this field. For example, Switzerland and Liechtenstein use a four digit post code format and the UK postcodes contain alphanumeric characters i.e. a combination of both letters and numbers.
To report invoices received cross-border, businesses should use a self-invoice (autofattura) which is also known as an integration document.
The required tax amount field should be populated using the tax shown on the actual invoice i.e. zero in the majority of cases as exports of goods and services will likely qualify for exemption or will be specifically outside the scope of Italian VAT.
There are specific document type codes (TipoDocumento) relating to the reporting of invoices received, including:
Type
| Code
|
Purchase of services from abroad
| TD17
|
Intra-community acquisition of goods
| TD18
|
Other purchases of goods from foreign vendors
| TD19
|
