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Some important updated concerning mandatory e-invoicing obligations in Italy such as soft landing and digital signatures and how invoices should be stored.


A soft landing and no longer real-time submission

The Italian tax authorities announced a soft-landing period and abandoned a real-time submission. The new legislation, however, still comes in force on January 1, 2019.

Italy has changed real-time invoice reporting timeline and announced a soft-landing period until 1 July 2019.  Resident taxpayers were supposed to submit their sales invoices on the day these invoices were issued to the tax authority’s platform for approval. The tax authorities forwarded any approved invoices to customers for VAT processing and payment approval. On 23 October 2018 (Law decree number 119), however, the following changes have been announced:

From 1 January 2019 till 1 July 2019 invoices do not have to be submitted to the SdI platform real time but ultimately on the 15th of the month following the month of invoice issue. The tax authorities will in principle not raise tax penalties when that deadline is not met.  That is however different when invoices are still not submitted by the 15th of the second month following the invoice issuing month.  In that case, a tax penalty of 20% is due. After 1 July 2019, invoices have to be submitted to the SdI platform within ten days after issuing.

Non-resident Italian VAT registered businesses will not be required to comply with the new SdI declarations.

Digital signature not mandatory for B2B

Based on the Circular letter published by Italian Tax authorities on April 30th, digital signature is not mandatory for B2B and B2C transactions however it is highly recommended to use it.

This was also validated in a recently published information bulletin by Agenzia Entrate on October 4th:

For all electronic invoices sent to private individuals (other VAT operators or final consumers), the SdI also accepts files that are not digitally signed. In the event that, however, the electronic invoice file is digitally signed, the tax authorities are executing checks on the validity of the signature certificate.

How electronic invoices are stored

According to article 39 of Presidential Decree No. 633/1972) both the issuer and the recipient of an invoice electronics are legally obliged to archive this invoice electronically.

Such electronic storage is not a simple PC storage of the file.

The Italian law regulates the process technically via the Code of Digital Administration (CAD). This electronic preservation process guarantees over the years that invoices will not be lost and are available to read them and, the original can be recovered at any time (as well as other computer documents that you decide to bring in conservation).

Operators usually provide the standard electronic storage process. These are certified private individuals easily identifiable on the Internet. However, the Revenue Agency provides also an electronic retention service free of charge for all invoices issued and received electronically through the System of Interchange. This service is accessible by the user from his reserved area of the " Fatture e Corrispettivi" portal: please refer to the section " I servizi gratuiti offerti dall’Agenzia delle Entrate " for further information.

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Written by Richard Cornelisse
 Richard LinkedIn

Richard advises multinational businesses in improving the efficiency and effectiveness of their Indirect Tax Function and Tax Control Framework.

He started his career as a manager at Arthur Andersen and then became a partner in EY where I led the indirect tax performance team for Netherlands and Belgium. Currently, he is a senior managing director of KEY Group.

Richard has over 20 years’ experience advising clients on international VAT issues. He is specialized in the tax aspects of financial transformations, shared service center migration, and post-merger integration work. Richard is also somewhat of a mentor, giving back to the profession. If you are interested in conversation and discussion, please feel free to contact him.