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VAT Refund Denied to Non-Residents with Italian Permanent Establishment, Even for Direct Purchases

  • Non-resident entities with a permanent establishment (S.O.) in Italy are excluded from VAT refunds.
  • This exclusion applies even if purchases are made directly, without involvement of the Italian branch.
  • The issue was only marginally addressed in Italian Revenue Agency response no. 33/2025.
  • In the cited case, a German company with an Italian S.O. could not recover excess deductible Italian VAT, even for direct transactions.

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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