Edited by Andrea Werner Beilin, Francesco Maria Mariani, and Nicola Manglaviti
Following Provision no. 369141/2025 of October 9, 2025, the Italian Tax Authorities have initiated the transmission of so-called “compliance letters” to taxpayers for the year 2023.
These communications, based on paragraphs 634 – 636 of Law no. 190/2014, aim to report any anomalies identified through cross-referencing data available to the Italian Tax Authorities.
The checks are mainly based on:
- the data from electronic invoices issued for the transfer of goods and services between parties residing or established in Italy, pursuant to Article 1, Legislative Decree no. 127/2015, and towards the Public Administration, based on Article 1, Law no. 244/2007;
- the electronic daily fees transmitted electronically to the Italian Tax Authorities, pursuant to Article 2, Legislative Decree no. 127/2015;
- the information contained in the annual VAT return, related to the year 2023.
Within the communication are reported:
- the taxpayer’s personal data;
- the identification number of the communication and the tax year;
- the act code;
- the total of taxable VAT operations and those subject to reverse charge transmitted electronically;
- the methods for consulting the details of the anomalies;
- instructions on how to request clarifications or report unknown elements to the Italian Tax Authorities;
- methods to regularize one’s position.
It is reminded that, once the compliance letter is received, the taxpayer is allowed to:
- request information from the Italian Tax Authorities or provide justifying elements for the detected anomalies, also through appointed intermediaries referred to in article 3, paragraph 3, D.P.R. no. 322/1998;
- regularize one’s position through voluntary correction (see article 13, Legislative Decree no. 472/1997), benefiting from the reduction of the penalties provided for the violation.
PwC Tax STP is available to assist taxpayers in identifying any discrepancies close to the VAT return deadline, anticipating the checks carried out by the Italian Tax Authorities.
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