Italian Tax Agency Clarifies VAT Transfer Rules in Business Lease and Transfer Cases

The rules for business leasing also apply to transfer and contribution.
The VAT ceiling cannot be transferred to the transferee unless mentioned in the contract governing the business transfer.
If the transferee is a foreign entity, it must be identified for VAT purposes in Italy either directly or through a tax representative.
This was clarified by the Italian Revenue Agency in response to inquiry number 200 published on August 4, 2025.
The case involves a complex corporate reorganization with three parties: an Italian company transferring a business branch to a UK legal entity, which partially contributes it to a newly established company in Italy.

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.