Italy targets VAT reverse charge at labour-intensive logistics contracts, with an interim client-pays option
This page records one dated change. For the rules in Italy as they stand today, see the Italy guide →
- Jurisdiction
- Italy
- Tax
- VAT
- Change type
- Compliance
- Status
- In force
- Impact
- FYI
- Announced
- 31 December 2024
- Effective
- 1 January 2025
- Authority
- Gazzetta Ufficiale della Repubblica Italiana
- Verified
- Fetched from official source · high confidence
Contractors supplying labour-intensive services to goods-transport, goods-handling and logistics businesses in Italy, and those client businesses.
No action — monitoring only.
Law 30 December 2024, n. 207 (Legge di Bilancio 2025, GU n. 305 S.O. n. 43, 31 December 2024), Art. 1, commi 57-63, replaced lett. a-quinquies) of Art. 17, sixth paragraph, DPR 633/1972 to apply the VAT reverse charge to service contracts, subcontracts and similar arrangements characterised by predominant use of labour at the client's premises with the client's capital goods, rendered to businesses carrying out goods transport, goods handling and logistics services (excluding public bodies and entities under art. 17-ter and employment agencies under D.Lgs. 276/2003 art. 4). The reverse charge's effectiveness is conditional on an EU Council derogation under Article 395 of Directive 2006/112/EC (comma 58). Pending that, comma 59 lets the supplier and client opt, for three years, for the client to pay the VAT on the supplier's behalf (joint liability), notified to the Agenzia delle Entrate (commi 60-61). The rule was amended by DL 84/2025, art. 9 (see it-reverse-charge-logistics-dl84-2025). Commi 57-63 were later repealed by the Testo Unico IVA (D.Lgs. 10/2026) with effect from 2027.
What changed in detail
Law 30 December 2024, n. 207, the 2025 Budget Law (Gazzetta Ufficiale n. 305, supplemento ordinario n. 43, of 31 December 2024), Article 1, commi 57 to 63, deals with VAT on labour-intensive service contracts in the logistics sector.
Comma 57 replaces letter a-quinquies) of the sixth paragraph of article 17 of DPR 633/1972. The reverse charge now applies to services rendered under contracts, subcontracts and similar arrangements that are characterised by predominant use of labour at the client’s premises with the client’s capital goods, where the client is a business carrying out goods transport, goods handling or logistics. Supplies to public administrations and other entities covered by article 17-ter are excluded, as are employment agencies under article 4 of D.Lgs. 276/2003.
Under comma 58, the reverse charge takes effect only once the Council of the EU authorises a derogation under Article 395 of Directive 2006/112/EC. Pending that, comma 59 lets the supplier and the client opt for the client to pay the VAT in the name and on behalf of the supplier, who stays jointly liable. The supplier issues the invoice under article 21 of DPR 633/1972. The client pays the VAT under article 17 of D.Lgs. 241/1997, with no offsetting allowed. Under commi 60 and 61, the option lasts three years and is notified to the Agenzia delle Entrate.
What it means
In practice, the comma 59 option was the operative rule, because the reverse charge itself could not apply without EU authorisation. Logistics clients that opted in took on paying the VAT for their contractors, which removes the risk of a contractor collecting VAT and failing to pay it over.
The scope was soon rewritten. DL 84/2025, Article 9, deleted the labour, premises and capital-goods condition, and its conversion law deleted the employment-agency exclusion. It also extended the option to contractor and subcontractor relations (record). As of November 2026, Normattiva’s consolidated article 17 still makes letter a-quinquies) conditional on the Article 395 authorisation. Commi 57 to 63 are repealed from 2027 by the VAT Testo unico, D.Lgs. 10/2026 (record).
Proof
il prestatore e il committente possono optare affinchè il pagamento dell'imposta sul valore aggiunto sulle prestazioni rese sia effettuato dal committente in nome e per conto del prestatore, che è solidalmente responsabile dell'imposta dovuta.the supplier and the client may opt for the value added tax on the services rendered to be paid by the client in the name and on behalf of the supplier, who is jointly liable for the tax due.
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