In a significant regulatory update on the 15th April 2025, the Italian Revenue Agency (Agenzia delle Entrate) has introduced a new requirement that will impact non-EU businesses wishing to conduct intra-community transactions within the European Union.
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Source GVC
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- New Guarantee Requirement for Non-Residents: As of April 14, 2025, non-resident entities in the EU or EEA that fulfill VAT obligations through a fiscal representative must provide a suitable guarantee to request or maintain inclusion in the VIES database, as mandated by the Italian tax authorities’ provision.
- Specific Conditions for Providing Guarantees: Non-residents not yet holding a VAT number must provide the guarantee with their declaration of activity, while those with an existing VAT number but not included in VIES must submit the guarantee before their inclusion request. For those already in VIES, the guarantee must be submitted by June 13, 2025, or they risk exclusion.
- Guarantee Details and Verification Process: The required guarantee must be for at least 36 months and a minimum of €50,000, provided via government securities or a bank guarantee. After submission, the Italian tax authorities will verify the guarantee’s compliance and inform the applicant of the outcome before they can request inclusion in the VIES database.
Source PwC
