Ruling – non-resident Italian entities with non taxable activities can be part of a VAT group

Italian tax authority confirms that a non resident company can be identified in Italy for VAT purposes with the sole scope to participate at the VAT consolidation regime “IVA di gruppo” (art. 73 of Presidential Decree 633/1972) – i.e. even without carrying out any relevant transaction for VAT purposes. That means that for a foreign holding company the identification in Italy according to article 35-ter of Presidential Decree 633/1972 is enough to set-up the VAT consolidation

Source 2019 12 26 Ruling VAT grouping

Unofficial translation in English 2019 12 26 Ruling VAT grouping EN

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