New Requirements for Fiscal Representatives in Italy
Italy has introduced new requirements for fiscal representatives consisting of a declaration of honorability and a monetary guarantee.
The Italian government has introduced stricter requirements for fiscal representatives of foreign entities, aimed at combating VAT fraud and strengthening tax compliance.
Latest Update: Non-EU Businesses Making Intra-EU Transactions
On April 14, 2025, the Italian Revenue Agency issued Provision No. 178713, outlining the operational procedures for financial guarantees required from non-EU businesses that wish to engage in intra-Community transactions through a tax representative in Italy.
Under Article 35 co. 7-quater of Presidential Decree 633/72, non-EU entities must:
- Be identified in Italy via a fiscal representative, and
- Provide a financial guarantee as a condition for inclusion in the VIES (VAT Information Exchange System) database.
The guarantee must be submitted in favor of the Director of the Provincial Directorate of the Revenue Agency where the fiscal representative is domiciled, and it may take one of two forms:
- Government or state-backed securities
- A surety bond or bank guarantee.
This new mandate implements procedures previously introduced in the Ministerial Decree of December 4, 2024, and clarifies the framework to ensure compliance, transparency, and tax security for non-EU businesses operating in Italy via fiscal representation.
New Requirements for Tax Representatives in Italy
- Subjective Requirements: Fiscal representatives must meet specific criteria of honorability, including:
- No convictions or pending criminal proceedings for financial crimes.
- No history of significant or repeated violations in tax or contribution matters.
- Objective Requirements: Fiscal representatives must provide a guarantee in the form of:
- Government bonds guaranteed by the State, or
- A bank or insurance guarantee.
- The guarantee must cover a minimum period of 48 months and is mandatory from the date the role is assumed, which is marked by the submission of the guarantee to the competent tax office.
From a practical perspective, tax representatives must certify their compliance with subjective requirements via a self-declaration submitted to the competent tax office, and provide the required guarantee.
Which entities must appoint a fiscal representative in Italy? Our Italian VAT manual has the answer.
Implementation Timeline
The measures were implemented through the decree issued on 9 December 2024 by the Deputy Minister of Economy. What's next?
- A Revenue regulation detailing operational procedures will be issued within 120 days.
- Once this regulation is published, Italian tax representatives must submit the self-declaration and provide the guarantee within 60 days from the publication of the provision. Failure to comply will result in the ex officio cessation of VAT numbers for the represented entities.
How Can Marosa Help You?
Marosa provides fiscal representation services to foreign companies in Italy. We have already started to get ready for the new requirements in order to be compliant in time. Contact us if you want to learn more about our VAT compliance software and services in Italy.