Summary
- Italy’s Revenue Agency has implemented a procedure allowing it to calculate VAT where a taxpayer omits its annual VAT return. Provision No. 239129/2026 permits automated processing using information already available to the authority, including electronic invoices, telematic receipts, periodic VAT settlement communications and VAT payments recorded for the relevant period. [agenziaent…ate.gov.it]
- Where the calculation identifies VAT payable, the Revenue Agency will communicate the result to the taxpayer, generally by certified electronic mail. The taxpayer has 60 days from receipt to provide relevant information or clarification. If electronic delivery fails, the authority may send the notification by registered mail with acknowledgement. [agenziaent…ate.gov.it]
- Taxpayers paying within the 60-day period can prevent direct collection of the settled amount, with the applicable omitted-return penalty reduced to one third. Italian entities should reconcile e-invoices, telematic receipts, periodic settlements and payments promptly, because inconsistencies in digital records may directly influence an authority-generated VAT calculation. [agenziaent…ate.gov.it]
Article
The Italian Revenue Agency issued Provision No. 239129/2026 on 28 August 2026, implementing a procedure for calculating VAT where a taxpayer fails to submit an annual VAT return.
The procedure gives effect to Article 54-bis.1 of Presidential Decree No. 633 of 26 October 1972. It allows the Revenue Agency to calculate VAT using automated procedures without preventing it from undertaking wider assessment activity. A return containing no information on taxable outgoing operations may also be treated as omitted for this purpose. [agenziaent…ate.gov.it]
The authority may use data from electronic invoices issued and received, telematic daily receipts, periodic VAT settlement communications and VAT payments made for the period under review. The VAT liability is generally determined by taking output tax shown in issued e-invoices, telematic receipts and periodic communications, then deducting eligible input tax found in received e-invoices and periodic communications, together with relevant payments. [agenziaent…ate.gov.it]
The procedure does not take account of a VAT credit resulting from the annual return for the preceding period. This limitation may be significant for taxpayers carrying forward substantial credits, particularly where a filing failure prevents that position from being reflected automatically. [agenziaent…ate.gov.it]
Where the calculation identifies VAT payable, the authority communicates its findings to the taxpayer. Delivery is generally through certified electronic mail, or PEC, using the address in the national INI-PEC register or a designated digital domicile. Registered mail with acknowledgement may be used where electronic delivery is unsuccessful. [agenziaent…ate.gov.it]
The taxpayer has 60 days from receipt to identify data that were not considered, point out information evaluated incorrectly or provide clarification. The communication and an analytical schedule identifying the e-invoices and telematic receipts used in the calculation are also made available electronically in the taxpayer’s tax account. [agenziaent…ate.gov.it]
Payment within 60 days prevents collection, in whole or in part, of the amounts settled through this procedure. In that case, the penalty is reduced to one third, while applicable interest remains payable. [agenziaent…ate.gov.it]
Italian businesses should monitor annual return filing controls and reconcile digital VAT records before submission deadlines. The measure does not create a new e-invoicing obligation, but materially increases the enforcement value of data already held by the authority.
Source Links
Italian Revenue Agency Provision No. 239129/2026, dated 28 August 2026 [agenziaent…ate.gov.it]
