Edited by Luca Lavazza, Pier Francesco Berardinelli, Giorgio Sapia
The logistics and transport market has recently been the focus of particular attention by the Public Prosecutor’s Offices of multiple Italian cities and the Illegal Activities Contrast Sector of the Italian tax authorities, which intercepted a series of fraudulent behaviors for tax and social security purposes. Among the main issues, it emerged that many service providers tended to collect the VAT charged to their clients, without then making the necessary tax payments to the Treasury.
To prevent this phenomenon and protect clients who regularly paid VAT to their suppliers, the 2025 Budget Law[1] has introduced an optional VAT regime with special tax payment rules.
In particular, pending authorization from the Council of the European Union for the extension of the mechanism of the reverse chargeand with regard to the services provided to companies engaged in transport, goods handling and logistics activities, the service provider and the client may agree that the payment of VAT related to such services is made directly by the client to the Treasury on behalf of the service provider, who remains jointly and severally liable for the tax due. Taxpayers can opt for the special regime through the electronic submission by the client of the “Communication form of the option for services provided to companies engaged in transport, goods handling and logistics services” (hereinafter “Communication”), approved by the Provision of the Director of the Italian tax authorities no. 309107/2025, published on July 28, 2025. The electronic submission must mandatorily occur through the software “Reverse Charge Communication in the Logistics Sector”, provided by the Italian tax authorities.
The form requires the indication of data relating to the parties and the contract for which the option is exercised, which has a three-year duration starting from the date of electronic submission of the Communication. In case of multiple contracts between the same parties, it is possible to submit a single Communication by filling out multiple forms to indicate the data relating to each contract concluded and subject to the special regime.
Regarding the invoicing methods and through a FAQ dated September 10, 2025, the Italian tax authorities clarified that the service provider is obliged to issue an invoice indicating taxable amount, VAT rate and VAT, including the annotation “Opzione IVA a carico del committente ex articolo 1, comma 59, legge n. 207 del 2024” (i.e., “VAT option paid by the client under Article 1, paragraph 59, Law no. 207 of 2024”). Furthermore, “if the parties, for management purposes, deem it useful”, it is possible to populate fields 2.1.3.2 (with the default value “RCLogistica”), 2.1.3.5 (with the electronic protocol number of the Communication) and 2.1.3.3. (with the corresponding date). In light of the clarifications provided in the subsequent FAQ of October 15, 2025, in cases where the service provider uses precompiled VAT documents, these fields must be filled in to ensure correct VAT allocation in such documents.
With reference to the booking obligations, the service provider must register the invoices issued under the optional regime separately in the VAT sales register, reporting separately the VAT which, not being collected and paid to the Treasury, does not contribute to either the provider’s periodic or annual VAT settlement. As for the client, the obligation to register the invoices in the VAT purchase register remains in order to exercise the right to deduct the VAT paid on behalf of the provider.
The burden shifted to the client is, therefore, exclusively the payment of VAT, without the possibility of offsetting it, to be executed on behalf of the provider by the 16th of the month following the date of invoice issuance by the provider. The payment must be made via the F24 form, using the tax code “6045”, introduced by Resolution letter no. 47/E of 28 July 2025. Additionally, Resolution letter no. 53/E of October 7, 2025 introduced the identification code “66”, called “Jointly liable party for VAT reverse charge logistics”, to be indicated in the F24 form together with the tax code of the provider (or subcontractor), respectively in the sections “identification code” and “Tax code of the jointly liable party, heir, parent, guardian or bankruptcy trustee”. It follows that it seems possible to make a cumulative payment of the VAT due monthly for each supplier, but not a single payment for more suppliers.
Despite the clarifications provided by the Italian tax authorities, doubts remain about the reference date for determining the payment deadline. Reasonably, the issue date should be the one indicated in the “Date” field of the e-invoice. However, this conclusion seems to expose the client to the risk of substantial penalties if the supplier submits the invoice late to the SdI or in some cases of rejection by the SdI[2]. It therefore appears essential to closely monitor the passive flow and protect oneself at the contractual level.
PwC TLS is available to assist companies operating in the transport and logistics market for the drafting of the contract to jointly opt for the special regime, of the compilation and of the electronic submission of the Communications, identifying tax risks borne by the parties and any other tax assistance activity.
[1] Law No. 207 of December 30, 2024.
[2] The issue becomes relevant whether an invoice is submitted to SDI during the month following that indicated in the document date: for example, if an invoice, issued following adherence to the transitional regime, indicated the document date as November 28, 2025, and was submitted to SDI on December 3, 2025, the question would arise whether the deadline for VAT payment by the client on behalf of the provider is December 16, 2025, or January 16, 2026.
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