The transfer of inventory existing in Italy as part of a transfer of going concern carried out abroad is an autonomous supply of goods for VAT purposes.
A corporation without a business in Italy, the Italian tax authorities clarified that also the transfer of inventory existing in Italy between the applicant and the acquiring company, acting as the purchaser of a business existing abroad, cannot be considered outside the scope of VAT according to article 2, paragraph 3, letter b), Presidential Decree no. 633/1972. On the contrary, the transfer of inventory should be qualified for VAT purposes as an autonomous supply of goods, according to article 2, paragraph 1, Presidential Decree no. 633/1972, which, considering that the goods are existing in Italy, is relevant for VAT in Italy from a territorial point of view according to article 7-bis, Presidential Decree no. 633/1972.
Source
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