Edited by Andrea Werner Beilin, Cristina Mosca and Luca Masotti
Article 1, paragraphs 634–636, of Law No. 190 of 23 December 2014 establishes that the Italian tax authorities shall make available for every taxpayer, or their intermediaries, data and information aimed to promote compliance and voluntary disclosure procedure, enabling them to report, if any, mistakes or discrepancies.
By provision No. 172588/2026 of 9 June 2026, the Italian tax authorities have announced the issuance of the so-called compliance letters to taxpayers showing anomalies in their 2026 VAT return, relating to the tax year 2025. Such anomalies have been identified through cross-checking of electronic invoices and daily consideration data carried out by the Italian tax authorities.
Specifically, the Italian tax authorities, based on data related to sales e-invoices, data on daily considerations recorded and transmitted electronically, and data included in the 2026 VAT return (year 2025), verify:
- The possible failure to submit the annual VAT return;
- The submission of the annual VAT return without completing the “VE” Section, or with reporting output transactions up to EUR 1,000, lower than the total VAT-relevant sales recorded in the same tax period;
- The submission of the annual VAT return without the “VJ” Section, despite the presence of purchase invoices subject to the reverse charge mechanism.
The communication is sent to the taxpayer via certified email (PEC) and is also available for consultation in the “Cassetto fiscale” and in the taxpayer’s web portal “Fatture e corrispettivi”.
We would highlight that, if a “compliance letter” is received, the taxpayer can:
- Request additional information from the tax authorities or provide clarifications regarding discrepancies identified; or
- Regularize its position through the voluntary disclosure procedure, as provided for in Article 13 of Legislative Decree no. 472/1997 paying reduced penalties.
In particular:
- In the event of failure to submit the annual VAT return 2026 (year 2025), the taxpayer can submit it within 90 days from the ordinary deadline of April 30, 2026, therefore by July 29, 2026. The taxpayer should pay higher VAT due, the interest and the reduced penalties under the voluntary disclosure procedure;
- Where the VAT return 2026 (year 2025) has already been submitted, the taxpayer can correct any mistake or omission by filing an integrative annual VAT return, paying the higher VAT, the interest and the reduced penalties under the voluntary disclosure procedure.
Finally, the other violations connected with the annual VAT return (e.g. missing registration of taxable transactions), must also be considered and paid as part of the voluntary disclosure procedure.
Let’s Talk
For a deeper discussion: