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New VAT Guidelines for Personnel Secondment: Clarifications from Italian Revenue Agency Circular No. 5

  • The Italian Revenue Agency issued clarifications on the new VAT rules for personnel secondment.
  • The reform under Article 16-ter of DL 131/2024 makes personnel secondment subject to VAT.
  • The previous national rule exempting secondments with only cost reimbursement was repealed.
  • VAT applicability depends on subjective, objective, and territorial criteria.
  • Secondments require business activity; non-commercial entities must verify business organization.
  • Secondments within the same VAT Group are generally not subject to VAT.
  • Secondments for consideration are considered service provisions.
  • A direct link between secondment and payment is necessary for VAT applicability.
  • Payment is considered a consideration if it is essential for the secondment operation.

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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