Italy's 2026 Budget Law sets the VAT base of barter transactions at the total costs of the supplies
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
- 30 December 2025
- Effective
- 1 January 2026
- Authority
- Gazzetta Ufficiale della Repubblica Italiana
- Verified
- Fetched from official source · high confidence
Italian VAT payers that exchange goods or services for other goods or services (permute) or settle debts by payment in kind (dazioni in pagamento).
No action — monitoring only.
Law 30 December 2025, n. 199 (Legge di Bilancio 2026, GU n. 301 S.O. n. 42, 30 December 2025), Art. 1, commi 138-139, amended Art. 13, comma 2, lett. d), of DPR 633/1972 on the VAT taxable base of barter transactions and payments in kind (art. 11 operations): the 'valore normale' (normal value) of the goods and services exchanged was replaced by their value determined as the total amount of all costs referable to those supplies. The rule applied to transactions carried out after the law entered into force on 1 January 2026, with earlier conduct safeguarded. DL 27 March 2026, n. 38, Art. 1, limited it to transactions under contracts concluded or renewed from 1 January 2026; the conversion law (L. 22 May 2026, n. 88) later repealed commi 138-139 and replaced the rule with a contract-value base.
What changed in detail
Law 30 December 2025, n. 199, the 2026 Budget Law (Gazzetta Ufficiale n. 301, supplemento ordinario n. 42, of 30 December 2025), Article 1, commi 138 and 139, changes the VAT taxable base of the transactions covered by article 11 of DPR 633/1972: barter (permuta) and payments in kind (dazioni in pagamento), where goods or services are supplied in exchange for other goods or services.
Comma 138 amends article 13, comma 2, letter d), of DPR 633/1972. Until then the base of each of these supplies was the normal value (valore normale) of the goods and services exchanged. The new text sets it as the value of those goods and services, determined by the total amount of all costs referable to the supplies.
Comma 139 applies the new rule to transactions carried out after the law entered into force on 1 January 2026, and preserves conduct adopted before that date.
What it means
This rule did not last. Decree-Law 27 March 2026, n. 38, Article 1, first narrowed it to transactions under contracts concluded or renewed from 1 January 2026. Its conversion law, L. 22 May 2026, n. 88, then rewrote that article. It repealed commi 138 and 139 and set the base at the monetary value stated in the contract, which cannot be lower than the total costs of each party’s supplies (DL 38/2026, art. 1, as converted). It saves conduct that followed comma 138 until the conversion law came into force, with no refunds or adjustments.
So the pure cost-based base is superseded. For contracts concluded or renewed from 2026, the contract value applies, with total costs as a floor. The same wording is written into article 27 of the VAT Testo unico, which applies from 1 January 2027.
Proof
« dal valore dei beni e dei servizi che formano oggetto di ciascuna di esse, determinato dall’ammontare complessivo di tutti i costi riferibili a tali cessioni o prestazioni »"by the value of the goods and services forming the subject of each of them, determined by the total amount of all costs referable to those supplies"
Source snapshot of the official page. Open full size ↗Archived from the official distribution · Gazzetta Ufficiale n. 301 del 30 dicembre 2025, Supplemento ordinario n. 42/L: Legge 30 dicembre 2025, n. 199 · www.gazzettaufficiale.it