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New VAT Rules for Employee Secondment Contracts Effective January 2025

  • Payment qualifies as compensation if there is mutual conditioning
  • For personnel secondment or loan contracts from January 1, 2025, only cost reimbursement is no longer exempt from VAT
  • Article 16-ter of DL 131/2024 repealed the provision that allowed VAT exemption
  • This change follows the EU Court of Justice ruling on March 11, 2020, case C-94/19
  • Services from contracts after January 1, 2025, are subject to standard VAT rules
  • The Italian Revenue Agency provided clarifications in circular no. 5/2025 regarding the tax’s scope

Source: eutekne.info

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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