On August 28, 2026, the Italian Revenue Agency published Provvedimento Prot. n. 239129/2026, which sets the implementing rules for determining the value added tax (VAT) due through automated procedures when a taxpayer does not file the annual VAT return, under Article 54-bis.1 of Presidential Decree No. 633/1972.
The rules reach taxable persons registered for VAT in Italy that do not file an annual VAT return, or that file one with no outbound transaction data at all. The provvedimento does not state a start date.
The Revenue Agency may make the calculation using automated procedures, from data it already holds:
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Invoice data from electronic invoices issued and received through the Sistema di Interscambio (SdI)
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Daily receipts transmitted electronically
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Periodic VAT settlement communications (Liquidazioni Periodiche IVA, LIPE)
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VAT payments made for the tax period under review
A return that reaches the Revenue Agency completely without the outbound transaction data needed to determine turnover and the tax due counts as omitted for these purposes.
The calculation disregards the credit arising from the return for the preceding tax period. A VAT credit carried forward from an earlier year falls out of the result, even where the taxpayer filed that earlier return correctly and the credit is valid.
The Revenue Agency acts by December 31 of the seventh year after the year in which the return fell due. A later assessment remains possible.
If the process results in VAT payable, the Revenue Agency sends the result by certified electronic mail to the taxpayer. The notice and the supporting schedule of invoices and receipts also appear in the “L’Agenzia scrive” section of the taxpayer’s cassetto fiscale.
The taxpayer has 60 days from receipt to pay, or to report data the Revenue Agency did not consider or evaluated incorrectly. Where the Revenue Agency recalculates the amount after those clarifications, a new 60 day period runs from receipt of the final notice. Payment within the 60 days reduces the penalty. Where the taxpayer does not pay in time, the Revenue Agency enters the tax, the full penalty, and interest directly on the collection roll.
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