Edited by Andrea Werner Beilin, Paola Bramato
As of July 1, 2025, companies listed on the FTSE MIB index of the Italian Stock Exchange, identified for VAT purposes, will be excluded from the split payment mechanism.
This exclusion results from the repeal of letter d), paragraph 1-bis, Article 17-ter of Presidential Decree 633/1972, as established by Article 10 of Decree-Law No. 84 of June 17, 2025.
This legislative change is part of the implementation of Council Implementing Decision (EU) 2023/1552, which authorized Italy to extend the application of the split payment system until June 30, 2026, but excluded transactions involving the aforementioned companies starting July 1, 2025.
In 2023, Italy had requested an extension of the measure, justifying it with the need to combat VAT evasion through cross-checks enabled by electronic invoicing. However, to comply with commitments made at the European level, the request was amended to provide for the exclusion of listed companies, with deferred effect.
Operational Implications for Suppliers
Starting July 1, 2025, suppliers of these companies must adjust their invoicing procedures, applying standard VAT rules, except in cases where the reverse charge mechanism o VAT exemption applies.
Specifically:
- the electronic invoice must no longer indicate the value “S” in the “tax point” field;
- the charged VAT must be included in the supplier’s periodic VAT return;
- the customer will pay the VAT to the supplier and may exercise the right to deduct it under the general rules.
Effective Date and Interpretative Clarifications
Article 10 of Decree-Law No. 84 of June 17, 2025 states that the new rules apply to transactions for which the invoice is issued from July 1, 2025.
However, given the possible mismatch between the invoice issuance date, the transaction date, and the tax point, an official clarification is expected, also in light of the previous guidance expressed in Circular No. 9/E of 2018, which linked the application of the new rules to both the invoice issuance and the tax point.
Let’s Talk
For further information:
Contatta Luca Lavazza – Partner, PwC TLS Avvocati e Commercialisti