- Alfa S.p.A. received funds from the Ministry under the National Recovery and Resilience Plan (PNRR)
- Alfa argues that the funds should be considered money transfers outside the scope of VAT
- Italian Revenue Agency’s analysis relies on Circular No. 34/E of November 21, 2013
- Key factors in determining VAT treatment include reciprocal exchange of services, arrangement of interests, and final beneficiary status
- Agency agrees with Alfa’s interpretation that the funds are mere money transfers
- Funds are exclusively for purchasing materials, not compensating Alfa
- Agency concludes that the funds can be classified as money transfers outside the scope of VAT
- Alfa’s right to deduct input VAT on purchases is a factual matter that requires a substantive audit
- The document mentions the split payment mechanism but doesn’t provide a specific conclusion on its applicability.
Source: agenziaentrate.gov.it
Note that this post was (partially) written with the help of AI. It is always useful to review the original source material, and where needed to obtain (local) advice from a specialist.
