Listed companies out of split-payment from 1 July 2025
Dear customer,
We hereby inform you that, starting from 1 July 2025, listed companies included in the FTSE MIB index of the Italian Stock Exchange, identified for VAT purposes (list available at the following link: https://www1.finanze.gov.it/finanze/split_payment/public/#/tabelle/2025/4), will be excluded from the scope of application of the split payment. This novelty derives from the Tax Decree approved by the Council of Ministers on Thursday 12 June.
Therefore, sellers and service providers carrying out transactions with the aforementioned companies must apply the ordinary regime and collect the VAT charged on them.
The aforementioned change intervenes directly on Article 17-ter of Presidential Decree 633/72 with the repeal of letter d) of paragraph 1-bis), which previously extended split payment also to transactions made to FTSE MIB listed companies.
Operational implications
This change requires attention both in terms of invoicing and for the management of accounting and internal automatisms: the invoicing automatisms will have to be updated by providing for a behavioral cut-off date as of June 30, 2025.
From a practical point of view:
- The supplier (transferor or supplier) will no longer have to indicate the “S” code (split payments) in the “VAT chargeability” field of the electronic invoice.
- The supplier (transferor or supplier) will have to include the VAT charged in the periodic VAT liquidation. In fact, active transactions carried out with companies listed on the FTSE MIB index of the Italian Stock Exchange will generate a VAT liability to be offset against the deductible VAT arising from purchases and imports.
- The customer (transferee or principal), upon payment of the invoice received, will pay the VAT to the supplier together with the amount due and may deduct VAT, keeping into consideration the ordinary limitations.
Therefore, the return to regular VAT chargeability eliminates the risk for suppliers to accumulate structural VAT credits, simplifying financial management.
Concrete application and practical cases
Suppliers must carefully assess how to proceed based on the billing date, observing the rules governing the transaction that affect the timing of invoice issuance.
Consider the case of a service contract entered into with a listed company, with monthly billing and application of the split payment regime.
In this case, the invoice is normally issued by the 5th day of each month for services rendered in the previous month. Therefore, the invoice for June 2025, issued on 5 July, will be subject to the ordinary tax regime, without the application of split payment. The absence of split payments in the invoice means that the issuer must include the VAT shown on the invoice in its periodic VAT liquidation, since the tax will no longer be paid by the listed company, which will, however, still be able to deduct the VAT and will not be required to make a double entry (purchases and sales).
On the other hand, for invoices dated, for example, 30 June 2025, even if received by the listed company after 1 July, the split payment regime will continue to apply.
Error handling in billing
In the event of incorrect use of the split payment regime from 1 July 2025:
- If split payment is incorrectly applied to an invoice dated July 2025, the listed company must request a credit note and ask to issue a new, corrected invoice (see circular 15/E/2015).
- If, on the other hand, split payment is incorrectly omitted on an invoice dated 30 June 2025, the listed company must still request the issuance of a correct invoice, applying the regime in force at the time of the transaction.
To clarify the billing procedures to be adopted, we propose a table summarising some cases that may arise:
| CASE | BEHAVIOUR |
| Invoices issued with a date of 1 July 2025 to be paid by listed companies | Split payment does not apply |
| Invoice issued and transmitted on 10 July 2025 to listed companies dated 30 June 2025 | Split payment must be applied |
| Invoice issued on 30 June 2025 received from a listed company during July 2025 without indication of the split payment regime | The listed company must request the credit note and the reissue with the split payment regime |
| Invoice issued on 1 July 2025 received by a listed company during July 2025 indicating the split payment regime | The listed company must request the credit note and reissue it without the split payment regime |
Lists of listed companies included in the FTSE MIB index of the Italian Stock Exchange, year 2025
Below is the updated list of listed companies concerned, complete with tax code and date of inclusion, for practical and operational feedback.
| Tax code | denomination | Date of inclusion in the list |
| 00348170101 | UNICREDIT S.P.A. | 17/10/2024 |
| 00401990585 | LEONARDO – JOINT-STOCK COMPANY | 17/10/2024 |
| 00484960588 | ENI SPA | 17/10/2024 |
| 00488410010 | TIM S.P.A. | 17/10/2024 |
| 00748210150 | RECORDATI INDUSTRIA CHIMICA E FARMACEUTICA S.P.A. IN BRIEF RECORDATI S.P.A. | 17/10/2024 |
| 00825790157 | SAIPEM S.P.A. | 17/10/2024 |
| 00860340157 | PIRELLI & C. S.P.A. | 17/10/2024 |
| 01392970404 | FINECOBANK BANCA FINECO S.P.A. | 17/10/2024 |
| 01886120540 | BRUNELLO CUCINELLI S.P.A. | 17/10/2024 |
| 03315240964 | AZIMUT HOLDING SPA | 17/10/2024 |
| 03656470360 | FERRARI N.V. | 17/10/2024 |
| 04642290961 | MONCLER S.P.A. | 17/10/2024 |
| 04923960159 | AMPLIFON S.P.A. | 17/10/2024 |
| 05779661007 | TERNA-NATIONAL ELECTRICITY GRID JOINT-STOCK COMPANY | 17/10/2024 |
| 06672120158 | DAVIDE CAMPARI – MILANO N.V. | 17/10/2024 |
| 08936640963 | INFRASTRUTTURE WIRELESS ITALIANE S.P.A. | 17/10/2024 |
| 11666900151 | INTERPUMP GROUP S.P.A. | 17/10/2024 |
| 11957540153 | A2A S.P.A. | 17/10/2024 |
| 12520180014 | IVECO GROUP N.V. | 17/10/2024 |
| 13144290155 | DIASORIN SPA | 17/10/2024 |
| 13271390158 | SNAM S.P.A. | 17/10/2024 |
| 94040720107 | ERG S.P.A. | 17/10/2024 |
| 97103880585 | POSTE ITALIANE SPA | 17/10/2024 |
| 97784450013 | STELLANTIS N.V. | 17/10/2024 |
| STMICROELECTRONICS N.V. | 17/10/2024 | |
| TENARIS S.A. | 17/10/2024 |
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It is recommended that the attention of the interested parties is that this circular constitutes initial information and application guidance on the rules and provisions commented on.
For obvious reasons of timeliness and brevity, it does not contemplate the complete and exhaustive treatment of the topics and does not intend to suggest binding decisions and/or behaviors.
We remain available for any or further clarification
With best regards
Baldazzi Zattera & Associati