Significant changes have been introduced to the VAT framework applicable to transport, logistics, and goods handling services, following the enactment of the 2025 Budget Law (Law No. 207/2024) and the subsequent Decree Law No. 84/2025.
Below is a summary of the key updates, with particular emphasis on the new VAT payment mechanism applicable to customers.
Introduction of an Optional VAT Payment Regime
Pending formal approval from the European Union for the implementation of the reverse charge mechanism, the Italian legislator has introduced an optional transitional regime. Under this regime, customers may elect to pay VAT directly to the tax authorities on behalf of the supplier, subject to prior notification to the Italian Tax Authorities (Provision No. 309107/E/2025 dated 28 July 2025).
Main Operational Features:
- the supplier continues to indicate VAT on the invoice, but does not collect the amount;
- the customer remits the VAT directly to the Tax Authorities, in the name and on behalf of the supplier;
- payment must be made via F24 Form by the 16th day of the month following the invoice date, and cannot be offset against other tax credits;
- the supplier retains joint and several liability for the VAT;
- the option must be jointly agreed by both parties and formally notified using the specific form issued by the Tax Authorities.
Scope of Application
The new regime applies to:
- services rendered to companies operating in the fields of transport, logistics, and goods handling;
- contractual chains and subcontracting arrangements, noting that the election by one party does not bind others, nor does non-election prevent others from opting in.
Following the amendment introduced by Decree Law No. 84/2025, the original limitation restricting application to contracts involving “predominant use of manpower” and “use of the customer’s capital equipment” has been repealed. The regime now also extends to contracts concerning the carriage of goods on behalf of third parties.
Potential Incompatibility with Road Haulage Tax Benefits
This new VAT mechanism may conflict with the accounting benefits afforded to road haulage operators. In the absence of specific guidance from the authorities, it is advisable to conduct a case-by-case assessment – particularly with respect to the benefits outlined under Article 74(4) of Presidential Decree No. 633/1972 (e.g., quarterly summary invoicing and deferred VAT settlement without interest or penalties).
Conclusion
This reform constitutes a structural measure aimed at reducing VAT evasion in high-risk sectors. However, the practical implications for contractors and service providers are significant and necessitate a careful review of existing contractual and organizational arrangements.
The Tax Team of LEXIA remains available to provide further insights and tailored support on the practical application of the above measures.
