Italy Clarifies E-Invoicing Rules on the Transaction Date

Gabriel Pezzato
July 4, 2019

From 1 July 2019, companies will benefit from an extension in the time frame from when an invoice must be issued.  Businesses can now wait for as long as 12 days to issue instant invoices after performing a transaction in Italy.

The new interval is a result of the changes introduced by the Italian Parliament during the analysis of the Law-Decree n. 34 from 30 April 2019. Until last week, companies were expecting to have a 10-day interval from the moment of supply during which they need to issue the legal invoice after 1 July considering the framework set in the Law-Decree 119, passed by the Italian Parliament at the end of last year. The changes have now been adopted and are effective, going beyond this and increasing the time frame to 12 days.

It is noteworthy that the Italian tax authority – the Agenzia delle Entrate – recently issued a circular document with clarifications about how companies must comply with the deadline in light of what was previously proposed to be the 10-day rule. Accordingly, along with the end of the temporary grace periods that have applied for fines during the course of this spring, suppliers will no longer be authorized to issue instant invoices during the entire VAT liquidation deadline period. The Agenzia delle Entrate also clarified that the new interval does not give rise to a new invoice type; and that neither the new deadline nor the general clarifications introduced by the Italian tax authority affect the date requirements of invoices regulated by any other specific rules, notably those set in the sections contained in Article 21 of the Italian VAT Decree.

New technical specifications for electronic invoices had been expected before July, but the Italian tax authority opted to avoid taking measures that could require taxpayers to bear costs associated with the implementation or with the revision of systems already in place. Instead, the circular issued by the Agenzia delle Entrate explained that companies issuing instant invoices within the 10-day interval (now overruled) must fill the “Data” field under the “Dati Generali” section with the transaction date and must not report the invoicing date. Consequently, the Italian tax authority will be able to cross-check the transaction date reported in the e-invoice and the moment when the invoice file was transmitted to the SDI to assess if the deadline has been met. The clarifications issued by the Italian tax authority should still be considered as valid even after the conversion of the Law-Decree n. 34; however, taxpayers must interpret the 10-day period considering the new more generous deadline of 12 days.

The Agenzia delle Entrate also clarified the fulfillment of the “Data” field for the issuance of deferred invoices. In such cases, the date of the last of a set of transactions embraced by a deferred invoice must be indicated in the above-mentioned field.

The Italian tax authority finally noted in its circular document that in exceptional circumstances where taxpayers are still allowed to issue paper invoices, both the transaction and the issuance dates must be written in the document.

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Gabriel Pezzato

Gabriel is a Regulatory Counsel at Sovos TrustWeaver. Based in Stockholm and originally from Brazil, he obtained a Law degree and a specialisation degree in Tax Law in his home country. Gabriel is also a LL.M. candidate in International and European Tax Law at Uppsala University in Sweden.
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