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Changes in Italian e-invoices mandatory as of January 2021

Italian tax authorities (Agenzia Entrate) have recently published new technical specification of electronic invoices – Fattura for B2B transactions and Fattura PA for B2G transactions.

Transmission of e-invoices in amended XML structure will be mandatory from 1st of January 2021. Till 31st of December 2020 old versions of e-invoices will still be acceptable. However, it is already possible to use new versions as well.

New document types available in Italian e-invoices

Each Italian e-invoice has a parameter describing its type – TipoDoumento. New versions of Fattura (1.6.1) and Fattura PA (1.3.1) introduce 11 new document type codes. That is significant increase of required description accuracy of transmitted invoices. Most importantly, as of January 2021 Italian taxpayers will have to transmit much more e-invoices through SdI (Sistema di Interscambio) than before.

For instance, intra-community acquisition of goods will need to be reported under new TD18 code. Formerly, because of no relevant TD code, such purchases have not been covered by e-invoicing requirement.

New transaction types available in Italian e-invoices

When issuing an invoice without VAT, Italian taxpayers have to provide a reference to relevant explanation. For example, a supply might be exempt from VAT or subject to local reverse-charge regime.

Fattura & Fattura PA contain special field dedicated for providing a reason behind no VAT invoices – Natura. From January 2021 more detailed information about nature of transaction will be transmitted to tax authorities.

For example, in old e-invoices it was only one value dedicated for reverse charge supplies – N6. Whereas, new e-invoices have 9 separate values (N6.1. to N6.9) dedicated for reverse charge transactions, depending on their exact nature. For instance, N6.2. – supplies of gold and silver, N6.6. – supplies of electronic products.

New contribution types available in Italian e-invoices

There is a field TipoRitenuta in Italian e-invoices applicable for contributions which need to be withheld in a special way in particular circumstances. New values RT03 to RT06 are introduced. For example, RT05 is relevant for ENPAM contribution. RT01 (natural persons withholding tax) and RT02 (legal persons withholding tax) have also been available in old e-invoice structure and remain in new one.

New version of SdI

In Italy, before a customer receives an invoice, the invoice has to be validated and pre-approved by Italian tax authorities. That is so-called tax clearance model, very common for example in Latin America.

Transmission of Italian XML e-invoices is done via SdI system (Sistema di Interscambio). As there are new technical e-invoice specifications amendment of SdI platform itself is required as well. New SdI version 1.8.1. version is in line with new Fattura and Fattura PA.

VAT reporting impact of changes in Italian e-invoices

At first glance, aforementioned changes may seem not big ones as they are related “only” to some selected fields. However, considering especially a great extension of TipoDocumento (document type) values VAT reporting impact on Italian taxpayers should be considered as significant.

In order to be in line with new e-invoices it is required to review transactions performed and verify whether new document codes or transaction nature codes are applicable.

However, most importantly, relevant changes in ERP system have to be reflected. It seems, even if a taxpayer does not perform any transactions covered by new TD or N codes, still IT changes might be required.  Primarily because as of January 2021 generated XML file containing e-invoice data will have to be in line with new technical specification.


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