- Italian Revenue Agency issued Answer No. 38 2025 on February 18, 2025.
- The answer clarifies VAT treatment of personnel secondments and loans between companies.
- Taxpayer A, an in-house company, provides IT services for its members.
- Taxpayer B, an instrumental body, manages health and social health activities.
- Taxpayer B requested temporary personnel from Taxpayer A.
- Taxpayer B argued that reimbursement of costs for seconded personnel should not be subject to VAT.
- The Tax Agency clarified that reimbursements made after January 1, 2025 are subject to VAT.
- The decision is based on a European Court of Justice ruling.
Source: news.bloombergtax.com
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