This circular reports for your attention the controls to be carried out by the end of the year for the registration of payable invoices.
- Deduction of purchase invoices and customs bills
Following the changes introduced by Decree-Law art. 2 no. 50 of 24.04.2017, the right to deduct VAT (pursuant to Article 19 of Presidential Decree 633/1972) on purchase invoices and customs bills must be applied by the end of the annual VAT Declaration for the year in which the tax became due (30th April 2025).
In order to exercise the right of deduction, as provided for by Article 25 of Presidential Decree 633/1972, it is necessary to have received the invoice, which must be registered in the appropriate register before the periodic liquidation in which the right of deduction is exercised, and in any case by the deadline for submitting the annual VAT Declaration for the year in which the invoice is received.
Therefore, the right to deduct VAT arises when the following conditions are met (Circ. 1/E 2018):
- The tax has become chargeable pursuant to Article 6 paragraph 5 of Presidential Decree 633/1972 (substantive requirement);
- The transferee or principal is in possession of a valid purchase invoice (formal requirement).
In the case the purchase invoices and customs bills received, it is specified that the deduction of VAT is exercised relating to the documents received and recorded by the 15th day of the month following the month in which the transaction was carried out.
- Year-end purchase invoices
The identification of the date of receipt of the invoice is a relevant moment for the identification of the moment from which VAT can be deducted.
It should be noted that the moment in which the transaction was carried out does not necessarily correspond with the date of issue of the invoice, since the invoice may be issued within 12 days from the moment in which the transaction was carried out (pursuant to Article 21 par. 4 of Presidential Decree N. 633/1972).
The date corresponding to the moment when the transaction is carried out is indicated on the invoice, while the date of receipt of the invoice, for electronic invoices, as also specified by the Revenue Agency in Circular N. 14/E/2019, is attested by the Interchange System (SDI).
In particular for:
- invoices dated 2024 and received within 31.12.2024: VAT may be deducted in the December liquidation, if the invoice is registered in the same month in which it is received or, at the latest, within 30.04.2025 (deadline for submitting the annual VAT Declaration for the year 2024), by booking the documents in a special section of the VAT register of 2024 (so-called 13th liquidation 2024);
- invoices dated 2024 received in 2025: in this case, VAT may be deducted in the year of receipt of the document (2025) and will be included in the liquidation of the month of 2025 in which they are noted in the register.
Following a summary table:
|
Invoice |
Registration |
Purchase VAT deduction |
|
|
Date of issue |
Date of receipt |
|
|
|
December 2024 |
December 2024
|
within December 2024 |
VAT liquidation for December 2024 (due within 16.01.2025) |
|
January-April 2025 |
• In the 2025 annual VAT Declaration, referring to 2024, to be submitted within 30.04.2025 and registered separately in the VAT purchase register (so-called 13th VAT liquidation 2024) |
||
|
From May 2025 (Invoices registered over the deadline of 30.04.2025[1] ) January-April 2025 (invoices registered within April 2025 but not included in the annual VAT Declaration referring 2024) |
• Purchases VAT not deductible or • Possibility of submitting a supplementary annual VAT Declaration |
||
|
2025
|
January – December 2025 |
In the VAT liquidation of the month in which the document is booked in the VAT register |
|
|
From January 2026 to April 2026 |
• In the 2026 annual VAT Declaration, referring to 2025, to be submitted within 30.04.2026 and registered separately in the VAT purchase register (so-called 13th VAT liquidation) |
||
|
From May 2026 (Invoices registered over the deadline of 30.04.2026) |
• Purchases VAT not deductible or • Possibility of submitting a supplementary annual VAT Declaration |
||
Examples are provided below to identify the moment of deduction of purchase invoices at the end of the year 2024:
|
Date of issue |
Date of receipt |
Date of registration |
Purchase VAT deduction |
|
December 2024 |
31.12.2024 |
31.12.2024 |
16.01.2025 (VAT liquidation for December 2024) |
|
December 2024 |
31.12.2024 |
9.01.2025 |
30.04.2025 In the annual VAT Declaration and registered separately in the VAT purchase register |
|
December 2024 |
31.12.2024 |
2025 (VAT Declaration 2026 referring the year 2025) |
VAT not deductible |
|
December 2024 |
10.01.2025 |
10.01.2025 |
17.02.2025 (VAT liquidation for January 2025) |
[1] Within the submission of annual VAT declaration
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