Important regulatory changes were introduced as a result of the 2015 Stability Law:

  1. SPLIT PAYMENT: the 2015 Stability Law Art.1 paragraph 269 stipulated that public entities no longer have to pay VAT to suppliers, but must pay it directly to the Treasury. Therefore, suppliers will not have to charge VAT on their invoices to their client public entities. Suppliers who issue invoices with withholding tax or reverse charge are not affected by this discipline. The new discipline applies to transactions invoiced on or after Jan. 1, 2015.
    Initial guidelines show the following:

    1. The sales invoice should continue to show vat and taxable income.
    2. A specification wording, such as “Art.17 ter Presidential Decree 633/72 VAT to be paid by the purchaser/transferee” should be displayed on the invoice
    3. A vat reversal line will need to be added to the invoice printout in order to correctly total the net payable
    4. The invoice should be noted in the VAT records but not considered in the settlement
    5. The vat line may not be charged to the generic vat debit account, but to a specific account that will not flow into the settlement, as it will close part of the credit to the customer, for the amount, precisely, of the vat
  2. SAP IMPACT:
    In case you issue invoices to PA you will need the:

    1. creation of a new vat code with the corresponding accounting account
    2. creation of a new dedicated document type
    3. change the layout of the sales invoice
    4. Automation, in the case of large volumes, of vat reversal writing
    5. creation of a dedicated vat registerATTENTION: all invoices issued to PA must follow these new rules as of Jan. 1, 2015. It is not yet clear whether the split payment will have an impact on the layout of the electronic invoice to the PA. We believe it will but no communication has yet been made in this regard.
  3. REVERSE CHARGE: Additional reverse charge assumptions have been introduced for certain transactions carried out under the domestic regime between taxable persons established in Italy.
    Specifically with reference to transactions concerning:

    1. Provision of cleaning, demolition, system installation and completion services related to buildings, regardless of the subjective qualification of the service providers/transferees.
    2. to transfers of greenhouse gas emission allowances operated, under the European Emission Trading Scheme (EU ETS), pursuant to Article 12, Directive No. 2003/87/EC;
    3. to transfers of other units that can be used by operators to comply with the same Directive No. 2003/87/EC, as well as energy and gas certificates;
    4. to supplies of gas and electricity to a taxable dealer, identified through the reference to Article 7-bis, paragraph 3 (a), Presidential Decree No. 633/1972.
  4. SAP IMPACT:
    In case you have to manage one of these types it will be necessary to create a new ad hoc vat sectional/register (new document type, new vat code, etc.)
  5. – INTRASTATSERVICES:The legislature has eliminated some fields from the intrastat services declaration. The fields to be completed will be as follows:
    1. VAT number counterparts
    2. Transaction value
    3. Service Code
    4. Country of payments
  6. SAP IMPACT:
    SAP is implementing the required regulatory changes. You will have to install the related note when it is released. We will be sure to keep you updated.

The Regesta Team is available to discuss the various issues in depth and provide you with the support you need.