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Italian Revenue Agency Clarifies VAT and PE Rules for Intra-Community Purchases

  • Italian Revenue Agency issued Letter No. 64 2025 on VAT treatment and PE rules for intra community purchases
  • German medical technology company indirectly controlled an Italian subsidiary company
  • Italian company purchased and resold goods of the German company
  • Italian company included a machinery expert who provided technical and application assistance
  • Taxpayer sought clarification on VAT treatment and expert’s role as PE
  • Tax Agency clarified that the expert did not intervene in intra community acquisitions due to lack of direct participation in contract negotiation and conclusion
  • Italian company was required to comply with tax obligations through the reverse charge mechanism

Source: news.bloombergtax.com

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.

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