
The short answer: a non-resident gets an Italian VAT number either by appointing a fiscal representative who registers on their behalf, by direct identification under article 35-ter of Presidential Decree 633/1972, or — when the plan is a real operating presence — through the Italian company itself at incorporation. The right route depends on where your business is established and what it does in Italy. This guide walks through the decision, the forms, the offices, the costs and what obligations follow the number.
Everything below is sourced from the Agenzia delle Entrate's own guidance, its English-language VAT registration pages and the primary legislation; the full list is at the end. Operational timings are in our companion piece, how long Italian VAT registration takes.
First check: do you need an Italian VAT number at all?
Italy's registration duty applies to anyone carrying on a business, art or profession in the country — but for foreign operators the trigger is narrower than most guides suggest. The Agenzia delle Entrate states plainly that a foreign operator does not need to register when its Italian customers are exclusively other VAT-registered businesses. The Italian buyer self-accounts for the VAT under the reverse charge, and no Italian number is involved on your side.
Registration becomes necessary when the situation includes any of the following
- Supplies to people or entities that cannot self-account: final consumers, non-businesses, exempt entities. Once you owe Italian VAT that only you can charge, you need the number.
- Holding goods in Italy: stock stored in Italian warehouses or fulfilment centres, goods under specific customs or VAT warehouse regimes, or imports where you are the party owing import VAT.
- Domestic distance selling to Italian consumers under the EU e-commerce rules, unless you have opted for the One Stop Shop.
- Specific regimes: goods placed in Italian VAT depots, excise-related distance sales, and similar cases listed in the professional guidance.
Two structurally different answers exist to that need. If the activity is genuinely local — hiring staff, contracting continuously, negotiating with Italian counterparties — the honest answer is usually not a VAT number but an Italian company, and the VAT registration comes with the company. The VAT-only routes below are for businesses that have Italian VAT obligations without wanting an establishment.
The two VAT-only routes, compared
| Direct identification (art. 35-ter) | Fiscal representative (art. 17(2)) | |
|---|---|---|
| Who can use it | Businesses established in another EU member state; businesses in non-EU countries with a mutual assistance agreement on indirect taxation with Italy | Any non-resident entity, EU or non-EU |
| Who holds the number | You, directly | The representative, registered in your name and on your behalf |
| Who files the returns | You (or your appointed intermediary) | The representative |
| Liability for the VAT | Yours alone | The representative is jointly and severally liable with you |
| Practical cost profile | Processing and translation; no ongoing mandate fee | Guarantee plus recurring representative fees |
| Form and office | ANR/3 to the Centro operativo di Pescara | AA9/12 or AA7/10, filed by the representative |
One more possibility exists for businesses with a real local footprint: a fixed establishment in Italy registers for VAT like a resident entity, using the ordinary forms. And a foreign entity may end up with two Italian VAT positions at once — for example a permanent establishment position plus a representative-managed position — which the Agency's own instructions acknowledge as legitimate but operationally delicate.
Route A: direct identification under article 35-ter (form ANR/3)
Direct identification gives the foreign business its own Italian VAT number to administer directly. The Agency reserves it for operators established in another EU member state or in a third country with which Italy has instruments of mutual assistance in indirect taxation; the catalogue of qualifying countries is maintained by the tax administration, so a non-EU business should confirm its country's status before planning around this route.
The mechanics are deliberately simple
- Complete form ANR/3 — the declaration for direct identification, variation of data or cessation of activity of non-resident VAT subjects. The attached instructions require identification details, the ATECO code of the activity and the operational details of the Italian transactions.
- File it before the first taxable transaction. The instruction is explicit: the declaration must reach the office before carrying out any operation relevant for VAT in Italy. Filing late is itself a violation even where the substantive tax ends up neutral.
- Send it to one office only: the Agenzia delle Entrate — Centro operativo di Pescara, via Rio Sparto 21, 65100 Pescara. Two channels exist: delivery by hand (in person or through a delegated person) or registered post, enclosing a photocopy of the declarant's identity document and certification of your VAT-registered status in your home state. The declaration is deemed filed on the dispatch date.
- Use ANR/3 again for changes and closure, within 30 days of the change, and for the cessation of the activity.
What direct identification does not waive: the ordinary Italian VAT obligations that follow the number — periodic settlements, the payments regime, the annual return, the INTRA lists for intra-EU flows, record-keeping in Italian tax form. Most directly identified businesses appoint an Italian professional for compliance even though no representative is imposed by law.
Route B: appointing a fiscal representative
Any non-resident entity — EU or not — may appoint a tax representative. For businesses established outside the EU (outside the mutual-assistance perimeter) this is not an option but the only route. The representative:
- is resident in Italy and holds an Italian VAT number of their own;
- registers for VAT in your name and on your behalf, filing the ordinary start-of-activity declaration — form AA9/12 if you are a sole trader or self-employed person, form AA7/10 for every other entity;
- files your periodic VAT settlements and returns, and can sign VAT payment forms on your behalf;
- is jointly and severally liable for your Italian VAT under article 17(3) of the decree — the very reason the role exists, and the reason it costs what it costs.
The appointment must be documented in an authentic deed, a registered private agreement or a letter filed in the register kept by the Revenue Agency office competent for the representative's tax domicile. Expect the representative, not you, to run that filing.
Two regulatory layers have tightened this route recently and are worth knowing before you compare quotes
- Requisites and guarantee of the representative. With the provvedimento of 17 April 2025, the Agency defined how representatives certify their subjective requisites (integrity requirements drawn from ministerial decree 164/1999) and scale a guarantee to the number of represented entities. A general guarantee for the role, not per client.
- Guarantee for non-EU represented entities. With the provvedimento of 14 April 2025, the Agency set the operational modes of the guarantee due, under article 35(7-quater), by non-EU and non-EEA established businesses that operate intra-community transactions through a representative — the model forms reference amounts of €50,000. The guarantee is in addition to the representative's own and is a real cash or insurance cost to budget.
Because the representative answers for your VAT, mandate agreements concentrate the duties, the access to your records and the exit terms. Our longer guide to the Italian fiscal representative covers liability, costs and the light-versus-full representation distinction in depth.
Route C: the VAT number comes with the company
Where the Italian activity justifies an operating entity, VAT registration is not a separate project. An SRL being incorporated files its start-of-activity declaration — form AA7/10 for the company — through the Comunicazione Unica, the single filing that simultaneously handles the Business Register, Revenue Agency, INPS and INAIL legs of the setup. The VAT number lands with the company's tax code.
For sole traders and professionals, form AA9/12 can be filed online through the Agency's services, at any office in duplicate, or by registered mail. Non-resident entities with a permanent establishment in Italy use the same forms and channels as residents.
If you are weighing a company against a bare VAT registration, our guides on opening an SRL as a non-resident and on Italian taxes for a foreign-owned company cover the corporate and income-tax side, including the permanent-establishment argument that a bare VAT number does not settle.
The codice fiscale dependency
The VAT filing needs a fiscal code for the foreign entity. For entities this is straightforward and usually handled inside the registration paperwork. For individuals, the codice fiscale is obtained from the Agenzia delle Entrate: through the Italian consulate of your country of residence, through a delegated person filing at an Italian office, or in person — and note that for a first codice fiscale the Agency now requires an in-person counter appointment for identity verification. The code is free; the time it takes is the planning variable, and it can become the first bottleneck of the whole timeline.
Costs: what the State charges and what the process costs
The State's part is free. The AA7/10, AA9/12 and ANR/3 forms carry no issue fee, the codice fiscale is free, VIES inclusion is free, and no stamp duty attaches to the registration communication itself.
Real money goes to three other lines
- Professional assistance. Drafting and filing a start-of-activity declaration, or an ANR/3 with its home-state certifications, is routine work for an Italian accountant; fees vary with complexity and with whether ongoing compliance is bundled.
- The fiscal representative. Recurring annual fees set by the market, plus the guarantee discussed above where one is due — a guarantee of the order of €50,000 under the 2025 models for non-EU businesses with intra-community operations, in cash, bank guarantee or insurance form.
- Translations and documents. The ANR/3 route wants proof of your home VAT status and an identity document; post-filing, certified translations and apostilles on corporate documents are the recurring friction of being a foreign number-holder.
Where an SRL is being formed, the VAT registration adds nothing material: it rides on the Comunicazione Unica inside the incorporation budget.
After the number arrives: the obligations that follow
Registration is the start of the compliance cycle, not the end of the project. What follows
- VIES inclusion. Request it in the registration itself (the intra-community operations field of quadro I for AA7/AA9 filers; the corresponding option for ANR filers) or later through the Agency's online services. The Agency includes the number in VIES immediately upon receipt of the option. Inclusion is withdrawn after four consecutive quarters without INTRA lists, effective from the sixtieth day after notice — so file the lists even in quarters with no intra-EU activity. Verify your number in the European Commission's VIES checker before the first cross-border invoice.
- Invoicing. The 11-digit number goes on every invoice and relevant document. Invoices to Italian VAT-registered customers from abroad stay outside the SdI exchange — the Italian customer's reverse-charge documentation does the work — while purchases of cross-border services and goods from abroad by the registered non-resident are documented through document types TD17, TD18 and TD19, which also replace the old esterometro communication. San Marino flows are the standing exception, with electronic rules of their own.
- Settlements, payments, returns. The periodic VAT settlement and payment calendar, the annual VAT return, and the INTRA lists for intra-EU supplies and purchases apply from the first period of activity. Non-resident number-holders interact with the Agency through their fiscal representative or their appointed intermediary.
- Changes and closure. Any change to the registered data goes on the same forms within 30 days — ANR/3 for the directly identified, AA9/12 or AA7/10 for the others — and cessation of activity follows the same pattern. An Italian VAT number is never transferred from one business to another.
- OSS and IOSS, if you sell to EU consumers. The One Stop Shop schemes are optional registrations, separate from the Italian VAT number, that centralise EU consumer-facing VAT in one member state. If your Italian registration exists for B2B reasons and your B2C EU volume runs through OSS, the two must be kept distinct in the books.
Common mistakes the Agency's rules make easy to avoid
Registering before checking the reverse charge.
Italian B2B-only suppliers frequently need no Italian number at all; registering anyway buys a compliance burden without a corresponding obligation.
Filing the first transaction before the ANR/3 lands.
The identification must precede the first Italian taxable operation; getting the order wrong exposes the direct-identification route to challenge.
Treating the representative as a mailbox.
Joint and several liability means the representative is on the hook for your VAT; the good ones will underwrite you, demand guarantees and expect full records. A representative who asks nothing is a warning, not a bargain.
Forgetting the VIES clock.
A VAT number without VIES inclusion blocks intra-EU invoices in both directions, and inclusion lapses after four silent quarters.
Assuming e-invoicing from day one.
The SdI perimeter follows residency and establishment, not the mere existence of an Italian VAT number; the cross-border document types, not ordinary e-invoices, document most foreign-flavoured flows.
Getting the number is the easy part
The forms are few and the offices are identified; what foreign businesses actually struggle with is the calendar, the interaction with corporate setup and the compliance cycle that follows. That is the part we do daily.
If you want the registration handled with the filings, the VIES position and the invoicing setup coordinated by an Italian team that works in English, the services page describes how we work with foreign-owned companies and pricing explains the fees. You can request a quote for your specific case; for the wider picture see Italian taxes for a foreign-owned company, the distinction between codice fiscale and VAT number, and the SRL tax deadlines calendar.
Primary sources
- Agenzia delle Entrate — VAT registration (English): obligation, non-resident routes, forms, OSS/IOSS
- Agenzia delle Entrate — Identificazione IVA soggetti non residenti, modello ANR/3: come si presenta
- Agenzia delle Entrate — Istruzioni per la compilazione del modello ANR/3 (PDF)
- Agenzia delle Entrate — Normativa e prassi, registrazione IVA per soggetti non residenti tramite rappresentante fiscale
- Agenzia delle Entrate — Provvedimento 17 aprile 2025, prot. 186368/2025: requisiti soggettivi e garanzia del rappresentante fiscale (art. 17, comma 3)
- Agenzia delle Entrate — Provvedimento 14 aprile 2025, prot. 178713/2025: garanzia ex art. 35, comma 7-quater, per soggetti non UE/SEE con rappresentante fiscale
- Normattiva — DPR 633/1972, articolo 17 (soggetti passivi, rappresentante fiscale), articolo 35 (dichiarazioni d'inizio attività) e articolo 35-ter (identificazione diretta)
- Agenzia delle Entrate — Inclusione nell'archivio VIES: che cos'è, modalità, inclusione immediata ed esclusione e compilazione e invio via web
- Agenzia delle Entrate — Tax identification number for foreign citizens (codice fiscale dall'estero, appuntamento di persona per la prima richiesta)
- Agenzia delle Entrate — Guida alla compilazione delle fatture elettroniche e dell'esterometro, v. 1.10 aprile 2025 (TD17/TD18/TD19, operazioni con l'estero)
- Agenzia delle Entrate — FAQ fatture verso e da soggetti stranieri (perimetro SdI nelle operazioni transfrontaliere)
- Commissione europea — Controllo partite IVA comunitarie (VIES) e Registro Imprese — Comunicazione Unica d'impresa
