VAT CONSOLIDATED ACT – Operational guide ahead of 1 January 2027

1. Introduction

By Legislative Decree no. 10 of 19 January 2026, the legislator carried out a comprehensive reorganisation of the national VAT rules, bringing together in a single text the provisions contained in Presidential Decree no. 633/72, Decree-Law no. 331/93, Decree-Law no. 41/95 and the main special provisions. The new VAT Consolidated Act applies to transactions carried out from 1 January 2027, while the previous rules continue to apply to transactions up to 31 December 2026.

In terms of content, the Consolidated Act is therefore essentially compilatory in nature: it reorganises pre-existing provisions into a single body of legislation, giving them new sequential and systematic numbering.

The new text also contains a series of authentic-interpretation and coordination provisions which broadly confirm already settled positions, as well as introducing clarifications or minor adjustments.

The legislator did not intend to alter in any way the logic or the mechanisms of the tax, which remains firmly anchored to the principles of charge-on (rivalsa) and deduction laid down at EU level; rather, it has eliminated the fragmentation of national legislation built up over more than 50 years of often chaotic amendments.

The topics included in the VAT Consolidated Act are arranged, in principle, on the basis of the table of contents of Directive 2006/112/Ce. In this way, national provisions are, for the most part, organised consistently with EU rules.

In summary, the new order in which the provisions are arranged in Legislative Decree 10/2026 is as follows:

  • subject matter and scope of application (Title I);
    • territorial scope of application (Title II)
  • examination of taxable persons (Title III);
  • rules governing the objective requirement of the tax / taxable transactions (Title IV);
  • place of taxable transactions (Title V);
  • chargeable event and chargeability of the tax (Title VI);
  • taxable amount (Title VII);
  • rates (Title VIII);
  • exemptions and non-taxable transactions (Title IX);
  • charge-on and deduction (Title X);
  • turnover and carrying on of more than one activity (Title XI);
  • obligations of taxable persons (Title XII);
  • collection (Title XIII).

These are followed by: refunds, VAT Group, special schemes and exemption (franchise) schemes.

The move to the new legislative framework makes it necessary to update VAT handling in accounting and ERP systems, in order to align VAT reason-code descriptions, the legal references shown on invoices and internal control procedures.

In order to assist operators in the transition from the previous legislative framework to the new codified structure, an xls mapping table based on the text of Legislative Decree no. 10 of 19 January 2026 (Consolidated Act of the legislative provisions on value added tax) is attached to this circular.

The xls table “Raccordo_DLgs_10_2026_Testo_unico_IVA” matches the previous rules — with particular regard to Presidential Decree no. 633/72, Decree-Law no. 331/93 and Decree-Law no. 41/95 — with the corresponding 171 articles of the Consolidated Act, indicating for each provision the source rule, the article of Legislative Decree 10/2026 into which it has been merged, the relevant heading and its systematic placement (Title and Chapter). It should also be borne in mind that a single previous provision may flow into more than one article of the Consolidated Act, and that a single article of the Consolidated Act may bring together several source rules. Articles 157, 170 and 171 do not indicate any previous provisions transposed into them. The attached xls file “Raccordo_DLgs_10_2026_Testo_unico_IVA” is for reference purposes only and does not replace direct reading of the legislative text, to which reference should be made for any application assessment.

In addition, in light of the new legislative framework, paragraph 2.3 sets out an operational table prepared on the basis of circulars and practice documents issued over the years by the Italian Revenue Agency on electronic invoicing. The table lists the main scenarios and is not exhaustive. For some of the more recurrent scenarios, the table maps the previous rules against the new VAT Consolidated Act applicable from 2027 and indicates, for each of them, the type of transaction, the relevant Nature Code (N) and the Document Type (TD) to be used in the XML file. Please note, therefore, that the content may change following any subsequent clarifications that the Italian Revenue Agency may publish in the meantime.

2. Technical structure: Nature code and Document Type

In order to facilitate consultation of the above-mentioned table, a brief descriptive summary of the Nature code and the Document Type is set out below; these are two distinct technical classifications: the Nature code characterises the substantive transaction, while the Document Type characterises the documentary flow.

  • Nature code:

For transactions issued without VAT charged on the invoice, the electronic invoice file provides for a “Nature” field which identifies the underlying reason why VAT is not shown (excluded transaction, outside the scope, non-taxable, exempt, under the margin scheme or under reverse charge). The following classification currently applies.

  • N1 — Excluded under Art. 15: Excluded amounts: documented expense reimbursements, advances made in the name and on behalf of the customer, contractually agreed discounts/bonuses/allowances in kind — Art. 15 of Presidential Decree 633/1972.
    • N2.1 — Not subject — Transactions outside the territorial scope of VAT: Transactions not subject to VAT for lack of the territorial requirement — Arts. 7 to 7-septies of Presidential Decree 633/1972.
    • N2.2 — Not subject — Other cases: Transactions outside the scope of VAT for reasons other than territoriality; flat-rate/advantage scheme; cross-border exemption scheme (EU Directive 2020/285, Art. 70-quaterdecies et seq. of Presidential Decree 633/1972).
    • N3.1 — Non-taxable — Exports: Export supplies under Art. 8(1)(a), (b) and (b-bis) of Presidential Decree 633/1972; goods withdrawn from a VAT warehouse and transported outside the EU (Art. 50-bis(4)(g) of Decree-Law 331/1993).
    • N3.2 — Non-taxable — Intra-Community supplies: Intra-Community supplies under Art. 41 of Decree-Law 331/1993, including EU triangulations.
    • N3.3 — Non-taxable — Supplies to San Marino: Supplies to San Marino operators — Ministerial Decree of 21.06.2021.
    • N3.4 — Non-taxable — Transactions treated as exports: Transactions treated as exports under Arts. 8-bis, 9 and 72 of Presidential Decree 633/1972 (e.g. supplies to international bodies, supplies to vessels, diplomatic supplies).
    • N3.5 — Non-taxable — Following letters of intent: Supplies of goods/services to regular exporters holding a letter of intent — Art. 8(1)(c) of Presidential Decree 633/1972; the protocol number of the letter of intent must be shown in the dedicated “AltriDatiGestionali” block.
    • N3.6 — Non-taxable — Other transactions not counting towards the plafond: Non-taxable transactions that do not build up the export plafond (e.g. supplies to Campione d’Italia, transactions under Arts. 71 and 72 of Presidential Decree 633/1972).
    • N4 — Exempt: Transactions exempt from VAT — Art. 10 of Presidential Decree 633/1972 (e.g. financial, healthcare, educational and insurance transactions, exempt leases).
    • N5 — Margin scheme — VAT not shown on the invoice: Second-hand goods, works of art, antiques and collectors’ items — Decree-Law 41/1995 (global, analytical or flat-rate margin scheme); travel agencies — Art. 74-ter of Presidential Decree 633/1972.
    • N6.1 — Reverse charge — Supply of scrap and other recovered materials: Reverse charge — Art. 74(7) and (8) of Presidential Decree 633/1972.
    • N6.2 — Reverse charge — Supply of pure gold and silver: Reverse charge — Art. 17(5) of Presidential Decree 633/1972; Law 7/2000 (investment gold).
    • N6.3 — Reverse charge — Subcontracting in the construction sector: Reverse charge — Art. 17(6)(a) of Presidential Decree 633/1972.
    • N6.4 — Reverse charge — Supply of buildings: Reverse charge — Art. 17(6)(a-bis) of Presidential Decree 633/1972.
    • N6.5 — Reverse charge — Supply of mobile phones: Reverse charge — Art. 17(6)(b) of Presidential Decree 633/1972.
    • N6.6 — Reverse charge — Supply of electronic products: Reverse charge — Art. 17(6)(c) of Presidential Decree 633/1972 (games consoles, tablets, laptops, integrated-circuit devices).
    • N6.7 — Reverse charge — Services in the construction sector and related sectors: Reverse charge — Art. 17(6)(a-ter) of Presidential Decree 633/1972 (cleaning, demolition, installation of plant, completion of buildings).
    • N6.8 — Reverse charge — Transactions in the energy sector: Reverse charge — Art. 17(6)(d-bis), (d-ter) and (d-quater) of Presidential Decree 633/1972 (electricity, gas, energy certificates).
    • N6.9 — Reverse charge — Other cases: Residual reverse charge: purchases of services from non-resident persons (Art. 17(2) of Presidential Decree 633/1972), intra-Community acquisitions of goods, imports under simplified customs procedures, other cases not classifiable under the preceding codes.
    • N7 — VAT paid in another EU Member State: B2C distance sales with VAT paid in the consumer’s EU country (OSS/IOSS) — Arts. 40(3) and (4) and 41(1)(b) of Decree-Law 331/1993; telecommunications, broadcasting and electronic services — Art. 7-octies of Presidential Decree 633/1972; Art. 74-sexies of Presidential Decree 633/1972.
  • Document Type:

Document Types (TD), by contrast, identify the formal nature of the XML file transmitted to the Interchange System (SdI) and are as follows:

  • TD01 Invoice
  • TD02 Down payment/advance on an invoice
  • TD03 Down payment/advance on a professional fee note
  • TD04 Credit note
  • TD05 Debit note
  • TD06 Professional fee note
  • TD16 Integration of an invoice under domestic reverse charge
  • TD17 Integration/self-invoice for the purchase of services from abroad
  • TD18 Integration for the intra-Community acquisition of goods
  • TD19 Integration/self-invoice for the purchase of goods under Art. 17(2) of Presidential Decree 633/72
  • TD20 Self-invoice for regularisation and integration of invoices (under Art. 6(9-bis) of Legislative Decree 471/97 or Art. 46(5) of Decree-Law 331/93)
  • TD21 Self-invoice for exceeding the plafond
  • TD22 Withdrawal of goods from a VAT warehouse
  • TD23 Withdrawal of goods from a VAT warehouse with payment of VAT
  • TD24 Deferred invoice under Art. 21(4), third sentence, letter a) of Presidential Decree 633/72
  • TD25 Deferred invoice under Art. 21(4), third sentence, letter b) of Presidential Decree 633/72 80
  • TD26 Supply of depreciable assets and internal transfers (under Art. 36 of Presidential Decree 633/72)
  • TD27 Invoice for own consumption or free-of-charge supplies without charge-on of VAT
  • TD28 Purchases from San Marino with VAT (paper invoice)
  • TD29 Notification of omitted or irregular invoicing (Art. 6(8) of Legislative Decree 471/97). Used to report omitted or irregular invoicing by a supplier, replacing code TD20

2.3. Operational table mapping the current rules to the new VAT Consolidated Act, Nature and Document Type

Set out below is the table mapping the current rules (Presidential Decree 633/72 / Decree-Law 331/93) to the new rules (VAT Consolidated Act), also indicating the Nature of the transaction and the Document Type.

Type of transactionCurrent rule (Presidential Decree 633/72 – Decree-Law 331/93)Rule in the new VAT Consolidated ActNature of transactionDocument Type (TD) 
A. TRANSACTIONS EXCLUDED FROM THE TAXABLE AMOUNT 
Default interest, penalties, amounts for breach of contractArt. 15(1)(1), Presidential Decree 633/72Art. 29(1)(a), Legislative Decree 10/2026N1TD01, TD02, TD03, TD05, TD06, TD24, TD25 
Goods supplied by way of discount/bonus/allowanceArt. 15(1)(2), Presidential Decree 633/72Art. 29(1)(b), Legislative Decree 10/2026N1TD01, TD04, TD05 TD24, TD25 
Documented advances made in the name and on behalf of the customerArt. 15(1)(3), Presidential Decree 633/72Art. 29(1)(c), Legislative Decree 10/2026N1TD01, TD04, TD05, TD06, TD24, TD25 
Packaging/containers not returned, deposits/amounts due by way of VAT charge-onArt. 15(1)(4)-(5) and (2), Presidential Decree 633/72Art. 29(1)(d)-(e), Legislative Decree 10/2026N1TD01, TD04, TD05, TD24, TD25 
B. TRANSACTIONS NOT SUBJECT TO VAT (OUTSIDE THE SCOPE) 
Supplies of goods not located in Italy (warehousing/transit)Art. 7-bis, Presidential Decree 633/72Art. 15, Legislative Decree 10/2026N2.1TD01, TD04, TD05, TD24, TD25 
General services supplied to persons established outside ItalyArt. 7-ter, Presidential Decree 633/72Art. 17, Legislative Decree 10/2026N2.1TD01, TD04, TD05, TD06, TD24, TD25 
Services relating to immovable property located outside Italy (leases, maintenance, surveys, design, etc.)/Passenger transport services in proportion to the foreign leg/Restaurant and catering services/leasing, including finance leasing, and short-term hire of means of transportArt. 7-quater, Presidential Decree 633/72Art. 18, Legislative Decree 10/2026N2.1TD01, TD04, TD05, TD06, TD24, TD25 
Cultural, artistic, sporting, educational and trade-fair services performed outside Italian territoryArt. 7-quinquies, Presidential Decree 633/72Art. 19, Legislative Decree 10/2026N2.1TD01, TD04, TD05, TD06, TD24, TD25 
Intermediation, transport, work on tangible movable property and non-short-term hire of means of transport, based on the place of performance/use (B2C)Art. 7-sexies, Presidential Decree 633/72Art. 20, Legislative Decree 10/2026N2.1/TD01, TD04, TD05, TD06, TD24, TD25 
N7 for B2C telecommunications, broadcasting and electronic services with VAT paid in the consumer’s EU country through the OSS 
General B2C services supplied to non-EU customersArt. 7-septies, Presidential Decree 633/72Art. 22, Legislative Decree 10/2026N2.1TD01, TD04, TD05, TD06, TD24, TD25 
Electronic, telecommunications and broadcasting services supplied to private individuals, taxed according to the customer’s domicile/residence, with a single EUR 10,000 threshold (B2C)Art. 7-octies, Presidential Decree 633/72Art. 23, Legislative Decree 10/2026 (or OSS scheme)N2.1 (where the tax is not due in Italy)TD01, TD04, TD05, TD06, TD24, TD25 
 
Transactions outside the scope of VAT for lack of the subjective or objective requirement; flat-rate scheme under Law 190/2014; advantage scheme under Decree-Law 98/2011Art. 1(54)–(89), Law 190/2014; Art. 27, Decree-Law 98/2011These schemes remain outside the VAT Consolidated ActN2.2TD01, TD04, TD05, TD06, TD24, TD25 
Single-stage transactions (resale of monopoly goods, tobacco, newspapers and magazines, publishing, technical means for telecommunications services) with VAT paid upstreamArt. 74(1)(b), (c), (d), Presidential Decree 633/72Art. 139, Legislative Decree 10/2026N2.2TD01, TD04, TD05, TD06, TD24, TD25 
C. NON-TAXABLE — INTRA-COMMUNITY TRANSACTIONS
Intra-Community supplies of goods (ordinary intra-EU supplies)Art. 41(1)(a), Decree-Law 331/93Art. 39(1)(a), Legislative Decree 10/2026N3.2TD01, TD02 TD04, TD05, TD06, TD24, TD25 
Intra-Community B2C distance sales to consumers in another EU Member State with VAT paid in the Member State of destination through the OSSArt. 41(1)(b), Decree-Law 331/1993; Art. 74-sexies, Presidential Decree 633/1972 (OSS)Art. 39(1)(b); Art. 150, Legislative Decree 10/2026N7 TD01, TD04, TD05, TD06, TD24, TD25 
Intra-Community supplies under the call-off stock arrangementArt. 41-bis, Decree-Law 331/93Art. 40, Legislative Decree 10/2026N3.2TD01, TD04, TD05, TD06, TD24, TD25 
Chain transactions (intermediary operator)Art. 41-ter, Decree-Law 331/93Art. 41, Legislative Decree 10/2026N3.2TD01, TD04, TD05, TD06, TD24, TD25 
Domestic triangulation with delivery in another EU Member StateArt. 58(1), Decree-Law 331/93Art. 43(1), Legislative Decree 10/2026N3.2TD01, TD04, TD05, TD06, TD24, TD25 
D. NON-TAXABLE — EXPORTS AND TRANSACTIONS TREATED AS EXPORTS, INTERNATIONAL SERVICES AND OTHERS
Direct export (arranged by/in the name of the supplier)Art. 8(1)(a), Presidential Decree 633/72Art. 45(1)(a), Legislative Decree 10/2026N3.1TD01, TD04, TD05, TD24, TD25 
Indirect export (arranged by the non-resident customer)Art. 8(1)(b), Presidential Decree 633/72Art. 45(1)(b), Legislative Decree 10/2026N3.1TD01, TD04, TD05, TD24, TD25 
Supplies of goods dispatched to a third country to public authorities and development cooperation bodies in pursuit of humanitarian purposes, including development cooperation programmesArt. 8(1)(b-bis), Presidential Decree 633/72;Art. 45(1)(c), Legislative Decree 10/2026N.3.1TD01, TD04, TD05, TD24, TD25 
Supplies of goods/services to regular exporters (plafond, letter of intent)Art. 8(1)(c) and (2), Presidential Decree 633/72; Art. 1, Decree-Law 746/83; Art. 2, Law 28/97Art. 45(1)(d) and (2); Arts. 46-47, Legislative Decree 10/2026N3.5TD01, TD04, TD05, TD24, TD25 
Transactions treated as exports (Supplies of vessels used for navigation on the high seas and their equipment/Supplies of aircraft used by airlines operating chiefly on international routes and their equipment)Art. 8-bis, Presidential Decree 633/72Art. 48, Legislative Decree 10/2026N3.4TD01, TD04, TD05, TD24, TD25 
International services or services connected with international trade (international transport, hire of vessels and aircraft, services ancillary to transport, etc.)Art. 9, Presidential Decree 633/72Art. 49, Legislative Decree 10/2026N3.4TD01, TD04, TD05, TD24, TD25 
Transactions with the Vatican City and San MarinoArt. 71, Presidential Decree 633/72Art. 50, Legislative Decree 10/2026N3.3 (for supplies to San Marino)
N3.4 (for supplies to the Vatican City)		TD01, TD04, TD05, TD06 TD24, TD25 
Supplies to non-EU travellers (tax-free shopping)Art. 38-quater, Presidential Decree 633/72Art. 51, Legislative Decree 10/2026N3.6TD01, TD04, TD05, TD24, TD25 
Transactions with international bodies, the EU, NATO and diplomatic missionsArt. 72, Presidential Decree 633/72Art. 52, Legislative Decree 10/2026N3.6 (request from the purchasing body the specific form certifying entitlement to non-taxable treatment)TD01, TD04, TD05, TD24, TD25 
 
E. EXEMPT TRANSACTIONS
Financial and credit transactionsArt. 10(1), nos. 1), 3), 4), Presidential Decree 633/72Art. 37(1)(a), (c), (d), Legislative Decree 10/2026N4TD01, TD04, TD05, TD24, TD25 
Insurance and reinsurance transactions, life-annuity transactionsArt. 10(1), no. 2), Presidential Decree 633/72Art. 37(1)(b), Legislative Decree 10/2026N4TD01, TD04, TD05, TD24, TD25 
Healthcare services for diagnosis, treatment and rehabilitationArt. 10(1), no. 18), Presidential Decree 633/72Art. 37(1)(t), Legislative Decree 10/2026N4TD01, TD04, TD05, TD24, TD25 
Leases and supplies of buildings (residential and commercial), non-building land and agricultural businesses, exempt from VAT unless the seller/lessor opts for taxation.Art. 10, nos. 8), 8-bis), 8-ter), Presidential Decree 633/72Art. 37(1)(h), (i), (l), Legislative Decree 10/2026N4TD01, TD04, TD05, TD24, TD25 
Exempt transactionsArt. 10, Presidential Decree 633/72Art. 37, Legislative Decree 10/2026N4TD01, TD04, TD05, TD24, TD25 
F. SPECIAL SCHEMES — TAX NOT SHOWN ON THE INVOICE
Margin scheme (second-hand goods, art, antiques)Art. 36, Decree-Law 41/95Art. 143, Legislative Decree 10/2026N5TD01, TD04, TD05, TD24, TD25 
Special scheme for travel agencies and tour operators – VAT on the margin of the travel packageArt. 74-ter, Presidential Decree 633/72Art. 141, Legislative Decree 10/2026N5TD01, TD04, TD05, TD24, TD25 
Placing of goods into/withdrawal of goods from a VAT warehouseArt. 50-bis, Decree-Law 331/93Art. 53, Legislative Decree 10/2026N3.6
/ taxable on withdrawal		TD22/23 for withdrawal; TD18/19 for placing into the warehouse by an intra-EU/non-resident person. 
G. REVERSE CHARGE
Investment gold (by option) and industrial gold/semi-finished goldArt. 17(5), Presidential Decree 633/72Art. 64(5), Legislative Decree 10/2026N6.2TD01, TD02, TD04, TD05, TD24, TD25 
Subcontracting in the construction sectorArt. 17(6)(a), Presidential Decree 633/72Art. 64(6)(a), Legislative Decree 10/2026N6.3TD01, TD02, TD04, TD05, TD24, TD25 
Supplies of buildings with option for taxationArt. 17(6)(a-bis), Presidential Decree 633/72Art. 64(6)(b), Legislative Decree 10/2026N6.4TD01, TD02, TD04, TD05, TD24, TD25 
Cleaning, demolition, installation of plant, completion of buildingsArt. 17(6)(a-ter), Presidential Decree 633/72Art. 64(6)(c), Legislative Decree 10/2026N6.7TD01, TD02, TD04, TD05, TD24, TD25 
Supplies of mobile phonesArt. 17(6)(b), Presidential Decree 633/72Art. 64(6)(e), Legislative Decree 10/2026N6.5TD01, TD02, TD04, TD05, TD24, TD25 
Supplies of games consoles, tablet PCs, laptops, microprocessorsArt. 17(6)(c), Presidential Decree 633/72Art. 64(6)(f), Legislative Decree 10/2026N6.6TD01, TD02 TD04, TD05, TD24, TD25 
Transfers of greenhouse gas emission allowances/Transfers of other units usable by operators and of certificates relating to gas and electricityArt. 17(6)(d-bis), (d-ter), Presidential Decree 633/72Art. 64(6)(g)-(h), Legislative Decree 10/2026N6.8TD01, TD02, TD04, TD05, TD24, TD25 
Supplies of gas and electricity to resellersArt. 17(6)(d-quater), Presidential Decree 633/72Art. 64(6)(i), Legislative Decree 10/2026N6.8TD01, TD02, TD04, TD05, TD24, TD25 
Supplies of logistics and transport servicesArt. 17(6)(a-quinquies), Presidential Decree 633/72Art. 64(6)(d), Legislative Decree 10/2026 — Law 207/2024N.6.9TD01, TD02, TD04, TD05, TD24, TD25 
Supplies of scrap, waste, metal residues, waste paper, rags and offcuts of bone, hides, etc., recovered materialsArt. 74(7) and (8), Presidential Decree 633/72Art. 139(7) and (8), Legislative Decree 10/2026N6.1TD01, TD02, TD04, TD05, TD24, TD25 
H. DOCUMENT TYPES FOR INTEGRATIONS, SELF-INVOICES AND REGULARISATIONS
Invoicing for the integration of an invoice under domestic reverse chargeArt. 17(6), Presidential Decree 633/1972Art. 64(6), Legislative Decree 10/2026No Nature code in the integration document; the supplier uses N6.xTD16 
Integration or self-invoice for the purchase of services from abroad that are territorially relevant in ItalyArt. 17(2), Presidential Decree 633/1972Art. 64(2), Legislative Decree 10/2026No Nature code where VAT is shownTD17 
Invoicing of intra-EU/intra-Community acquisitions of goodsArts. 38, 46 and 47, Decree-Law 331/93Arts. 8, 97 and 98, Legislative Decree 10/2026No Nature code where VAT is shown
/N3.5 where the purchase is made under suspension		TD18 
 
Integration or self-invoice for the purchase of goods located in Italy from a non-established personArt. 17(2), Presidential Decree 633/1972Art. 64(2), Legislative Decree 10/2026No Nature code where VAT is shownTD19 
Self-invoice for the regularisation of an intra-Community acquisitionArt. 46(5), Decree-Law 331/93Art. 97(5), Legislative Decree 10/2026 for intra-EU transactionsNature code consistent with the transaction, where not subject/non-taxable/exemptTD20 
Withdrawal of goods from a VAT warehouse without immediate payment of VATArt. 50-bis, Decree-Law 331/1993Art. 53, Legislative Decree 10/2026No Nature code (VAT accounted for under the reverse charge)TD22 
Withdrawal of goods from a VAT warehouse with payment of VATArt. 50-bis, Decree-Law 331/1993Art. 53, Legislative Decree 10/2026No Nature code (VAT accounted for under the reverse charge)TD23 
Transactions with San Marino (purchases with VAT on a paper invoice)Rules on Italy–San Marino trade (Ministerial Decree 21/06/2021)Art. 50 and implementing provisions, Legislative Decree 10/2026No Nature code (VAT shown)TD28 
Notification of omitted/irregular ordinary invoicingArt. 6(8), Legislative Decree 471/97Penalty rules unchangedNature code consistent with the transaction, where not subject/non-taxable/exemptTD29 
I. SPLIT PAYMENT TRANSACTIONS
Supplies of goods and services to public authorities included in the lists (pure public administration)Art. 17-ter(1), Presidential Decree 633/1972; Ministerial Decrees of 23.01.2015 and 27.06.2017Art. 65(1), Legislative Decree 10/2026—TD01, TD04, TD05, TD06, TD24, TD25 
Supplies of goods and services to companies and entities under Art. 17-ter(1-bis) (extended split payment)Art. 17-ter(1-bis), Presidential Decree 633/1972; Ministerial Decree 09.01.2018Art. 65(2), Legislative Decree 10/2026—TD01, TD04, TD05, TD06, TD24, TD25 
 

3. Actions required from clients

The entry into force of the new VAT Consolidated Act, with effect from 1 January 2027, will have significant operational implications for the management systems used for bookkeeping and VAT compliance. As a result of the change in legal references, recording the same transactions may require the use of entirely new and different codes, reason codes and VAT codes compared with those previously used, according to the alignment approach adopted by each software house. The alignment work will also have to extend to the printing and reprinting of VAT registers, periodic VAT settlements and other outputs, including those relating to prior years, so that each document shows the VAT references applicable to the relevant year. In this regard, it should be noted that, while for standard non-editable codes the alignment can be carried out directly by the software houses, for codes customised by users the burden of alignment may fall on the users themselves, since automatic updating is not always possible. A similar need for alignment will affect the modules used to import electronic invoices in XML format, which in many cases interpret the content of specific fields — such as “AltriDatiGestionali” and “RiferimentoNormativo” — in order to identify particular legal references: from 1 January 2027 those procedures will have to search for both the old and the new legal reference.

In light of the above, clients are invited to take prompt action to align their management systems and documentary practices with the new legislative framework introduced by Legislative Decree 10/2026. In particular, we recommend carrying out a careful review of the VAT reason codes configured in the system, updating the automatic invoice descriptions — including those relating to non-taxable, exempt and reverse-charge transactions — with the updated legal reference, replacing the previous provisions.

Likewise, we suggest reviewing the documentary flows relating to integrations and self-invoices (TD16-TD23), with particular attention to transactions with foreign counterparties, intra-Community acquisitions and purchases from non-resident persons, and carrying out a review of the SAP codes or equivalent management-system codes in use, in order to verify that they are correctly matched to the Document Type, the Nature code and the new legal reference.

Please note. Incorrect classification of a transaction and failure to issue the integration document or self-invoice in reverse-charge cases are not merely formal breaches, since they affect the verifiability and timely payment of the tax. The case law of the Court of Cassation consistently treats these obligations as substantive.

We also stress the importance of carefully obtaining and retaining the supporting evidence for the transactions carried out — proof of customs exit, CMR or equivalent document, letters of intent and any other relevant item — so as to ensure full traceability and defensibility of the choices made in the event of an audit.

Finally, it remains understood that, for non-recurring, cross-border or real-estate transactions, transactions subject to the reverse charge or falling within special schemes, it is advisable to request a prior review by the Firm, in order to ensure the correct application of the new rules and to prevent issues arising on audit

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Interested parties are asked to note that this circular constitutes initial information and guidance on the application of the rules and provisions discussed.

For obvious reasons of timeliness and brevity, it does not provide a complete and exhaustive treatment of the topics covered and is not intended to suggest binding decisions and/or conduct.

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