When did the Italian Revenue Agency formally align its rules to allow SPVs in merger leveraged buyouts to deduct input VAT?

On 12 February 2026, the agency abandoned its restrictive practice, aligning with the Supreme Court and EU.

What does Resolution No. 7/2026 state regarding SPVs in merger leveraged buyouts?

It confirms that such SPVs qualify as VAT taxable entities and may deduct input VAT on transaction costs.

Which Supreme Court decisions recognized SPVs as engaged in preparatory activities for VAT deductibility?

Decisions Nos. 22608 and 22649 of August 2024.

How can taxpayers recover historical VAT on merger leveraged buyout transaction costs in Italy?

By using the refund mechanism under Article 30 ter of Presidential Decree No. 633/1972, supported by robust documentation.

Italy’s Tax Agency Aligns Rules with EU, Benefiting M&A Deals

Italy widens 2% AgCom levy to digital and platform revenues

VatCalc · 10 minutes ago

Italy's 2026 Budget Law introduces a 2% AgCom contribution on Italian‑sourced digital, media and platform revenues, effective March 2026. The levy applies to both Italian and non‑Italian entities, with per‑mille rates ranging from 0.05% to 0.2% across activity categories and a €100 de‑minimis threshold. Filing is required via AgCom's electronic portal, with penalties up to €130,000 for non‑compliance.

Italy's SDI: How the E-Invoicing Pioneer Shaped Europe's Digital Tax Future

SAFT Validator · 28 days ago

Italy became the first EU country to mandate electronic invoicing for all VAT‑registered businesses in 2019, expanding the requirement to micro‑businesses in 2024 and introducing FatturaPA v1.9 in 2025. The SDI clearance model has reduced the VAT gap and serves as a benchmark for the EU’s ViDA framework. The current EU derogation expires at the end of 2027, while the consolidated VAT code will take effect on 1 January 2027.

Italy 2026 proposes e2 customs handling fee small parcel imports

VatCalc · about 1 month ago

Italy has postponed its planned €2 customs handling fee for e‑commerce parcels from outside the EU until the EU-level fee takes effect on 1 July 2026. The fee would apply to parcels not exceeding €150 intrinsic value, covering both B2C and B2B shipments, and is expected to generate €123 million in 2026 and €245 million from 2027 onward. The EU will introduce an interim €3 levy from 1 July 2026 and a €2 levy from 1 November 2026, with plans to remove the €150 de‑minimis exemption in 2028.

Italy weighs fuel excise cuts as oil above $100 boosts VAT receipts

VatCalc · about 1 month ago

Italy is reviewing the activation of its "mobile excise" mechanism to offset the VAT windfall caused by rising fuel prices, after oil prices surged above $100 per barrel on 9 March 2026. The government is considering cutting fixed excise duties to balance the increased VAT receipts generated by higher pump prices.

Death of Professional: VAT Invoicing by Heirs

Commercialista Telematico · 2 months ago

Italian tax authority clarifies that heirs of a deceased professional must issue VAT invoices on behalf of the deceased and, if the VAT number has ceased, must request its reactivation to pay tax on compensation received after death.

Italy Tax Agency Clarifies Input VAT Deductibility for SPV Transaction Costs in Merger Leveraged Buyouts

Bloomberg Tax · 2 months ago

The Italian Revenue Agency issued Resolution No. 7/2026 on 12 February 2026, clarifying that SPVs can deduct input VAT on transaction costs in merger leveraged buyouts only if the taxpayer qualifies as a taxable person and the goods/services are used for taxable economic activities. Holding companies that merely own shares without management participation cannot deduct input VAT. The resolution also addresses the deductibility for holding companies acting as SPVs.