Owning Companies identified for VAT in Italy by a Fiscal Representative are not required to be accredited to the SDI – Interchange System (SDI – Sistema di Interscambio ) for the e-invoicing procedure introduced by the Italian Tax Authority (Agenzia delle Entrate) starting from January 2019.
Law Decree N. 119/2018 (art. 15) amends the Italian regulation that introduced the mandatory electronic invoicing starting from 1st January 2019 (art. 1, para. 6 of Law Decree no. 127/2015) according to Implementing Decision (EU) 2018/593 from 16 April 2018 – which authorized Italy to the widespread use of electronic invoices – specifying that the obligation applies only to subjects established within the State (Italy) and not to foreign subjects identified for Italian VAT purposes, but not residing therein. This amendment implements what had been anticipated by the tax Agency in its Circular Letter no. 13/2018.
Therefore Owning Companies do not have the obligation to issue electronic invoices (e-Invoice).
This means that the actual procedure does not change and each invoice relevant to VAT due on Charters – having fiscal applicability in Italy – will still need to be issued in hard copy (paper format).
Please note that all the paper invoices issued by suppliers will need to contain the following wording: “copia cartacea della fattura” (translated: hard copy of the invoice). This will allow the Owning Company to still be able to deduct the VAT debited by the supplier. A “courtesy-copy” of the same invoice can be sent by the supplier to the client in digital format (e.g. pdf file sent by email).
A full explanation of the e-Invoicing in Italy can be consulted on the EU official website or visiting the following link: https://ec.europa.eu/cefdigital/wiki/display/CEFDIGITAL/eInvoicing+in+Italy.
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