RESOLUTION NO. 35/E
Taxpayers Division
Central Directorate for Small and Medium Enterprises
Rome, 24/05/2021
The following question has been raised with the request for consultation specified in the subject line
ALFA (hereinafter the “Company” or the “Applicant”), which deals with the development of software for online payments using credit and debit cards, represents that as part of the activity carried out, it needs to put sellers of online goods and services in contact with merchants of goods and services online with the potential customers, facilitating the payment from of these last ones, according to the following operating modalities: after that the customer has purchased a product/service from the merchant and inserted a payment card, it suffers the debit only of a third of the total amount. In the arc of the 60 days In the following 60 days the remaining part is debited in two tranches. At the end of the At the end of the transaction, the Company acquires a non-recourse trade receivable for a price equal to the value of the remaining two tranches. The Instant does not charge no interest rate to the customer and does not apply any discount rate to the purchase price of the trade credit, but purchase price of the trade credit, but only charges a fee to the seller in respect of the processing of the payment with a with respect to processing the card payment. Asks for a general opinion on the correct approach from the tax point of view of the transactions put in place.
Source: gov.it
