Summary
- The Italian Revenue Agency has introduced a procedure allowing it to calculate VAT due where a taxpayer fails to submit its annual VAT return.
- The assessment may use electronic invoices, periodic VAT-settlement communications and VAT payments already made by the taxpayer.
- The taxpayer has 60 days after notification to provide information or pay the amount due. Payment within that period reduces the applicable penalty to one third.
Extended article
The Italian Revenue Agency has implemented a procedure allowing it to calculate VAT liabilities automatically when a taxpayer fails to file an annual VAT return.
Provision No. 239129/2026, issued on 28 August 2026, permits the authority to use information already available through Italy’s digital VAT infrastructure. The calculation may draw on electronic invoices issued and received, periodic VAT-settlement communications known as LIPE, and VAT payments previously made.
The taxpayer will generally receive a notification through certified electronic mail. Registered mail may be used if electronic delivery is unsuccessful.
Following receipt, the taxpayer has 60 days to provide additional information or explanations or to pay the amount calculated by the authority. Where payment is made within the 60-day period, the applicable penalty is reduced to one third.
The procedure does not create a new electronic-invoicing obligation. Its significance lies in the Revenue Agency’s use of invoice and periodic-reporting information to reconstruct VAT liabilities where the annual return is missing.
Taxpayers should therefore ensure that electronic-invoice data, LIPE submissions and VAT payments are mutually consistent. Differences between those sources could affect the authority’s automated calculation and may need to be explained within the response period.
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