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
- New Guarantee Requirement: As of 14 April 2025, the Italian Revenue has implemented a requirement for nonresident entities registered for VAT in Italy through a VAT representative to provide a guarantee to include their Italian VAT number in the VAT Information Exchange System (VIES) for intra-EU transactions.
- Guarantee Details: The guarantee must be valid for at least 36 months and have a minimum value of €50,000. Affected entities currently in the VIES database must submit their guarantees by 14 June 2025, or face removal from the database and potential disruption to their business operations.
- Compliance and Consequences: If a guarantee is not submitted within the specified timeframe, the tax authorities will initiate removal procedures from the VIES database, emphasizing the importance for nonresident entities to comply with this new requirement to maintain their ability to conduct intra-EU transactions.
Source EY
