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Interpretation of Article 2 of Ministerial Decree on Integrated Water Service Invoicing

  • The company [ALFA] is a regional in-house company that provides integrated water services.
  • The company has been entrusted with the Integrated Water Service (SII) for the entire regional area for a period of 30 years.
  • The company is obligated to issue invoices for the SII services to the final customers.
  • The company seeks confirmation regarding the applicability of Article 2 of Ministerial Decree 370/2000, which allows for the annotation of the amount collected in the register of consideration for water supply services.
  • The company believes that the annotation of invoices, even if issued electronically, does not trigger the anticipation of VAT payment.
  • A different interpretation would result in a financial burden for all SII operators.
  • The opinion of the Revenue Agency is not provided in the given text.


Note that this post was (partially) written with the help of AI. It is always useful to review the original source material, and where needed to obtain (local) advice from a specialist.


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