Prepared by Lorenzo Ontano, Luca Ghelli and Andrea Casalini
On August 3, 2022, the Italian Tax Authorities published the Ruling no. 417/2022 that confirmes that the economic operators, in order to deduct the import VAT related to the operations whose amount is lower than 300 euro, can issue a recapitulative document to be registered in the VAT ledgers on a monthly basis.
The article 6, paragraph 6, of the Presidential Decree no. 695/1996 states that “The invoices regarding the purchase of goods and services whose amounts is lower than 300 euro can be registered by the terms provided by the article 25, first paragraph, of the Presidential Decree no. 633, October 26, 1972 by means of a recapitulative document where are reported the invoice numbers, assigned by the recipient, related to those invoices the recapitulative document refers to, the total taxable basis, the total VAT amount divided per each applicable VAT rate”.
Based on the text of the law, the simplification seems not to be applicable to the importations registered in the VAT ledgers by means of customs bills (now replaced by the so-called “prospetto di riepilogo ai fini contabili”).
With the above-mentioned Ruling, the Italian Tax Authorities clarify that the simplification under discussion can be applied also to the importations whose amount is lower than 300 euro and carried out in the same month, that can be registered in the VAT ledgers by means the customs bills (now replaced by the so-called “prospetto di riepilogo ai fini contabili”).
In this respect, the recapitulative document must report the data indicated in the relevant customs declarations (e.g. the MRN numbers of the imports, the amount of the taxable base and the related import VAT), allowing the identification of the relevant customs operation and not hindering the control activities by the Authorities. The import operations that can benefit of such simplifications are the ones whose amount is lower than 300 euro. This threshold must be calculated based on the taxable basis on which is quantified the import VAT, including all components that contribute to the latter.
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