Any entity established in Italy is liable to submit their invoices to the SdI, and as there is no threshold even a single quarterly invoice subjects the issuer to this scheme. The Italian tax authorities offer taxpayers a free tax portal that they can use to submit their XML files, though - as this portal is only offered in Italian - a local professional might be required to guide you through the process. While the free tax portal can be adequate for small volumes, third party solutions often offer more suitable functionality for larger multinational companies.
In addition, the Italian government has recently announced that based on the data collected through e-invoicing, they will make available the following draft documents to taxpayers:
- VAT ledgers, regularly updated with collected information, from the first day until the last day of the month following the reference quarter;
- Quarterly VAT communications (Li.Pe.), available from the sixth day of the second month following the reference quarter.
Starting from 2022, the IRA will also make available the draft annual VAT return (from the 10th of February following the reference year). Taxpayers however retain the possibility to confirm or submit their own VAT return, based on their own calculations.
More details on the system
If you have your registered office or a branch in Italy, the following applies: E-invoicing was in principle not required for sales of goods or services from or to foreign companies. In fact, the Italian tax administration introduced a new requirement for these transactions in order to also cover transactions not settled via the SdI: the Esterometro, which will remain a requirement only until the end of 2021.
As of January 2022, the Esterometro will be abolished and cross-border transactions must be recorded by the SdI system. The data of transactions to or from non-resident subjects must be transmitted via the SdI in the same form as all other invoices. Specifically, the reverse-charge on AP cross-border invoices will be accomplished through an electronic self-invoice to be sent to the SdI; for example “the document type” code to be included in the XML needs to be properly identified depending on the underlying transaction and as foreign companies are not obliged to issue e-invoices and therefore likely do not have a PEC (certified e-mail address), the Italian taxpayer must enter a specific pre-set number in this field. The time frame in which foreign 'e-invoices' are submitted are as follows:
For sales invoices
- From 2022 all outbound invoices to non-Italian partners must be sent to the SdI system. Submission must take place within the issuing period of the invoice (typically immediately, as with regular invoices to Italian customers).
For purchase invoices
- From 2022 a copy of every invoice received from a non-Italian partner must be sent to the SdI via the so called auto-invoice mechanism. Copies must be submitted before the 15th day of the month following the transaction date, evidencing the transaction.
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Laurens van de Leur
Sr. VAT Compliance Specialist
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