Selling into Italy as a Foreign Company: VAT on Goods and Services (2026)

Most foreign companies arrive at this question in the wrong order. They ask whether they need an Italian VAT number, then look for a reason. The VAT number is the last step, not the first. Two determinations come before it: is the supply taxable in Italy, and if it is, who accounts for the VAT — you or your customer?

Those two answers decide whether you can invoice without Italian VAT, whether you must register, whether you can use the One Stop Shop, and whether the Italian customer must integrate your invoice or issue a self-invoice. This guide works through the decision for goods and services, business and consumer customers, and the four ways goods can be connected with Italy: held in Italy, moved from another EU country, imported from outside the EU, or exported.

It reflects the rules in force on 27 October 2026. It is a decision framework, not a substitute for advice on a specific contract: the place-of-supply result depends on facts such as who transports the goods, where ownership passes and whether an Italian structure actually intervenes in the sale.

The short map

What you sell	Customer	Italian VAT?	Who accounts for it	Italian VAT number?
General service (consulting, design, marketing)	Italian business	Yes, under article 7-ter(1)(a)	Italian customer, reverse charge (even if you are identified)	Normally no
General service	Italian consumer	Usually no; check the article 7-quater and 7-quinquies exceptions	Nobody in Italy	No
Telecom, broadcasting or electronic service	Italian consumer	Yes, subject to the EUR 10,000 simplification where it applies	You, through OSS or Italian registration	No, if OSS is used
Service connected with Italian property, events, transport or catering	Any	Yes, if within article 7-quater or 7-quinquies; for B2B events, physical access and access-related services only	Customer by reverse charge if B2B; for B2C, OSS where eligible or Italian registration	Usually no for B2B; for B2C, OSS or registration
Goods dispatched from another EU country	Italian business with a valid VAT number	Exempt intra-EU supply; Italian VAT on the customer's acquisition	Italian customer	No
Goods dispatched from another EU country	Italian consumer	Italian VAT above the threshold; non-EU sellers generally from the first sale	You, through OSS or registration	Depends
Goods already in Italy	Italian business	Yes	Customer by reverse charge, even if you are identified or represented	Not required for that sale
Goods already in Italy	Italian consumer	Yes	You, unless a marketplace is the deemed supplier	Direct sale: yes. Deemed-supplier sale: the platform's OSS or registration
Goods imported from outside the EU	Italian consumer, eligible non-excise goods in a consignment up to EUR 150	Import VAT; the distance sale is in Italy with IOSS (or where the supplier is importer)	You or the deemed supplier through IOSS, or VAT at import	No, if IOSS is used
Goods sold and exported outside the EU	Non-EU customer	No, if the export is documented	—	Depends on the export route and evidence

The table is a starting point. Each row has conditions, and several have exceptions that reverse the result.

Services to businesses: the customer usually accounts for the VAT

The general rule

Article 7-ter(1)(a) of Presidential Decree 633/1972 treats general services as supplied in Italy when they are rendered to a taxable person established in Italy. Article 17(2) of the same decree then places the VAT obligations on the Italian customer, not on the foreign supplier: the invoice is issued without Italian VAT and the customer integrates it (for an EU supplier) or issues a self-invoice (for a non-EU supplier), and accounts for the tax.

The Agenzia delle Entrate describes the mechanics in its guide to electronic invoicing and the esterometro. For services bought from a non-resident, the Italian customer transmits document type TD17, which both integrates the invoice for VAT and satisfies the cross-border data-reporting obligation. A foreign supplier that is not identified or represented in Italy does not file that document and does not need an Italian VAT return for the supply. That allocation does not change because you are identified in Italy or appoint a fiscal representative: the Agenzia has confirmed that reverse charge still applies where the foreign supplier is identified directly or through a representative, and that an invoice issued through the Italian VAT number is not relevant as an invoice for the supply (Resolution 21/E/2015; Answer 114/2023). Identification or representation matters for your own Italian obligations, such as B2C sales, intra-EU acquisitions or imports, not for turning a B2B sale into a VAT-bearing one.

This is the ordinary outcome for consulting, design, software development, marketing, legal and accounting services supplied to an Italian company. It is also why a foreign supplier can have Italian business customers for years without an Italian VAT number.

Who counts as a business

The dividing line is not simply whether the customer has a VAT number. Article 7-ter(2) treats several categories as taxable persons for place-of-supply purposes: businesses and professionals; entities and organisations referred to in article 4(4) of the decree, even when they act outside commercial or agricultural activity; and non-taxable entities that are identified for VAT. An Italian association or foundation receiving a service from abroad can therefore be a "business" customer for this rule, even if its activity is not commercial. The customer's status should be documented at onboarding, not inferred from the word "association" or from the absence of a VAT number. Status is functional: a professional who buys exclusively for private purposes is a consumer, and article 19 of Implementing Regulation 282/2011 does not allow a supplier to treat a private purchase as business merely because the customer has a VAT number.

The exceptions that override the general rule

Article 7-quinquies is narrower and splits by customer. For consumers, it covers services relating to cultural, artistic, sporting, scientific, educational, entertainment and similar activities, including fairs and exhibitions, the organiser's services and ancillary services, when the activities take place in Italy; access to events and access-related services are also covered. For business customers, only the service that grants the right of access to the event, and access-related ancillary services, are drawn to Italy; organisation, coordination or intermediation fees that are not the sale of the right of access stay under article 7-ter and are taxed where the business customer is established. The access rule presupposes physical attendance: where attendance is virtual, article 53 of the VAT Directive does not apply and the service generally falls back to the B2B general rule, taxed where the customer is established. The Agenzia confirmed the organisation/access distinction in Answer 94/2026.

The consequence depends on the customer. A B2B service connected with an Italian building is Italian-taxable; if you are a non-resident without an Italian permanent establishment, the Italian business customer can still self-assess under article 17(2). But a B2C service in the same categories is Italian-taxable and the consumer cannot reverse charge, so you need an Italian VAT position or another applicable scheme.

Streaming changes the analysis for consumers: where the cultural, educational or entertainment activity is streamed or otherwise made virtually available, the place of supply follows the customer's domicile rather than the place where the activity happens. An online course or a paid webinar sold to Italian consumers can therefore be Italian-taxable even though nothing is performed in Italy.

When an Italian permanent establishment changes the answer

Reverse charge under article 17(2) is displaced by article 17(4) where the non-resident carries out the transaction through a permanent establishment in Italy. In that case the supply is made by an Italian-established business: you charge Italian VAT and the customer does not self-assess.

The test is not the existence of a desk or a warehouse. Article 53 of Implementing Regulation 282/2011 requires a sufficient degree of permanence and a structure adequate in terms of human and technical resources, and the establishment must actually intervene in the sale. The Agenzia applied that test in answer 57/2023, stressing that administrative support, contract signing in the name of the parent or marketing activity is not by itself enough. A branch or a staffed Italian operation is a different matter; our guide to branch versus subsidiary covers the corporate side, and the Italian tax guide for foreign-owned companies covers the income-tax permanent-establishment question, which is separate.

Services to consumers: often outside Italian VAT

The default rule

For B2C services, article 7-ter(1)(b) taxes the service in Italy only when the supplier is established in Italy. A foreign supplier with no Italian establishment therefore does not charge Italian VAT on ordinary consumer services such as consulting, design or remote support. This is the part that surprises businesses accustomed to "destination" rhetoric: the EU does not apply destination taxation to every B2C service. It applies it to the listed exceptions and to telecommunications, broadcasting and electronic services.

The exceptions in articles 7-quater and 7-quinquies apply to consumers as well, so a service connected with an Italian property, an event in Italy, Italian transport or an Italian restaurant is Italian-taxable even when the customer is a private individual. Where that happens, the consumer cannot self-assess, and you must register in Italy or use an applicable special scheme.

Telecom, broadcasting and electronic services

Article 7-octies implements the destination rule for telecommunications, broadcasting and electronic services supplied to non-taxable customers. A SaaS product, a paid app, an e-book or a streaming subscription sold to an Italian consumer is Italian-taxable, whether the supplier is in the EU or outside it.

The compliance route is the One Stop Shop. An EU-established business can use the Union scheme; a business not established in the EU can use the non-Union scheme, which after the 2021 extension covers services supplied to non-taxable persons in the EU. The schemes are optional. If you do not use one, you register for VAT in Italy and file Italian returns. The Agenzia's OSS guidance explains the three schemes and the registration portal.

The EUR 10,000 threshold is narrower than it looks

Article 7-octies(2) is a simplification: the destination rule does not apply where the supplier is established in another Member State and not also in a further Member State, and the total EU-wide value of B2C telecom, broadcasting and electronic services plus intra-EU distance sales of goods did not exceed EUR 10,000 in the previous year and does not exceed it in the current one. Article 59c of the VAT Directive sets the same threshold. For goods dispatched from Italy, the corresponding domestic rule is article 41(1)(b) of Decree-Law 331/1993.

Two conditions are routinely missed. First, the threshold is calculated on all EU sales of the relevant kind, not on Italian sales alone. Second, it is available only to a supplier established in a single Member State. The Agenzia states this directly in its OSS FAQ: "the EUR 10,000 threshold applies only to a business established in a single Member State". A company established outside the EU does not meet that condition, even if it has one or more fixed establishments in the EU: the Commission's OSS guidance states that such a supplier cannot use the threshold because it requires establishment in one single Member State and nowhere else.

Goods: where the goods are decides more than who the customer is

The basic rule

Article 7-bis(1) treats a supply of goods as made in Italy when it concerns immovable property in Italy, movable goods located in Italy, or goods dispatched from another Member State and installed, assembled or put together in Italy by the supplier or on its behalf. The EU rule is the same: goods are taxed where they are when the supply takes place, or where dispatch begins, subject to the distance-sale and installation exceptions (European Commission, place of taxation).

Delivery terms do not decide this by themselves. Incoterms allocate cost and risk; the VAT place of supply follows the location of the goods and the timing of the supply under article 6 of the decree. A DAP sale of goods already in Italy is still an Italian supply. An FCA sale of goods that are still outside the EU, with the Italian customer acting as importer, is a different transaction altogether.

Goods moving from another EU country

For a B2B sale, the supplier's dispatch from one Member State to another is normally an exempt intra-Community supply under article 138 of the VAT Directive, provided the customer is a VAT-registered business identified in Italy and the transport is evidenced. The Italian customer then accounts for the acquisition under article 38 of Decree-Law 331/1993 and reports it with document type TD18. The foreign supplier does not charge Italian VAT and does not need an Italian VAT number for that sale, but it must be able to prove the movement and will normally have to include the transaction in its intra-EU listing in the country of dispatch.

If the customer is a consumer, the same movement is an intra-Community distance sale. The place of supply moves to Italy, subject to the EUR 10,000 threshold where it is available. If the customer is a business without a valid Italian VAT number, the exempt intra-EU supply is not available on those facts, and the transaction has to be reclassified.

Goods already in Italy

Goods held in Italy — in your own warehouse, at a third-party logistics provider or under a consignment arrangement — are already in the place of supply. A sale of those goods is an Italian supply. What follows depends on the customer, and this is where the reverse-charge discussion becomes practical.

Goods imported from outside the EU

Import sales do not follow a single rule. If the import and the customer are in the same Member State and the customer is liable for import VAT (the usual non-IOSS courier model), the distance sale is treated as made where the goods are when dispatch begins — outside the EU — and is not taxable in Italy; VAT is collected at import (article 32(1) of the VAT Directive; European Commission, Explanatory Notes, section 4.1.4). If IOSS is used, the place of supply is where the transport ends, i.e. Italy (article 33(c)). If the supplier or deemed supplier is liable for import VAT without IOSS, the place of supply is where the goods are imported (article 32(2)). Where the import Member State differs from the destination, article 33(b) applies. For low-value consignments (intrinsic value up to EUR 150), customs release in a Member State other than the destination is in practice reserved to IOSS sales (article 221(4) of the customs implementing regulation, OJ L 2026/1200); that constraint does not apply to consignments above EUR 150. Import VAT is separate from the supply. Who pays it depends on who is the importer of record: you, your Italian customer, or a customs representative. That choice also determines whether you can recover the import VAT through Italian returns and whether the sale itself is Italian-taxable.

For B2C consignments of an intrinsic value up to EUR 150, the Import One Stop Shop allows the seller to charge Italian VAT at checkout and declare it through a single EU portal; the import is then exempt from VAT. The IOSS does not cover goods subject to excise duties (article 369l of the VAT Directive), and it does not apply above EUR 150. A non-EU business normally registers through an intermediary. The exception is narrow: the business must be established in a third country with a mutual-assistance agreement and the goods must be dispatched from that country; if it also ships from other countries, it needs an intermediary (the Commission gives the Norway example in its OSS registration guidance). Above EUR 150, IOSS is not available and VAT is collected at import.

Goods installed or assembled in Italy

If you dispatch goods from another Member State and install, assemble or put them together in Italy, article 7-bis(1) treats the supply as Italian. This is a common trap for machinery, equipment and fitted furniture. The installation is not a separate service that can be ignored: it can move the whole supply into Italy.

Goods exported outside the EU

A sale of goods located in Italy to a customer outside the EU can be non-taxable under article 8 if the goods are exported and the export is documented. Where the supplier arranges the export, the customs document or customs endorsement on the invoice is the evidence. Where the customer is a non-resident and exports within 90 days of delivery, article 8(1)(b) requires customs or postal endorsement on a copy of the invoice. Without that proof, the sale remains a taxable Italian supply even if the goods physically leave Italy. The export label does not by itself settle whether you need an Italian VAT position: where you sell goods located in Italy and act as exporter, you may need one to issue the export invoice and support the customs evidence. Check the route before assuming that "export" means "no Italian VAT number".

B2B sales from Italian stock: reverse charge is not the same as registration

What the Agenzia's invoicing guide describes

The Agenzia's guide to electronic invoicing and the esterometro addresses this case in substance

the non-resident seller, without a permanent establishment in Italy, invoices the sale of goods already present in Italy (which are therefore not imports or intra-Community acquisitions) to an Italian resident or established customer, showing the taxable amount but not the VAT, because the operation, from the seller's side, is not subject and is taxable in Italy, and the tax is paid by the customer.

That is the article 17(2) mechanism, and the customer uses document type TD19 to integrate the invoice or issue a self-invoice. The guide adds the important qualification: reverse charge does not apply, and TD19 must not be used, where the non-resident made the supply through an Italian permanent establishment (article 17(4)).

An Italian VAT number does not change the B2B treatment. Even if you are identified under article 35-ter or act through a fiscal representative, the Italian business customer must apply reverse charge to goods already in Italy. Resolution 21/E/2015 treats an invoice issued through the Italian VAT number as not relevant for VAT, and Answer 114/2023 confirms that reverse charge applies even where the foreign supplier is identified or represented. Registration can still be necessary for other flows, but it does not convert these B2B sales into Italian-VAT-bearing supplies.

Why you might still register

The fact that reverse charge applies does not make registration irrelevant. Four reasons commonly change the decision.

First, input VAT. If you incur Italian VAT on imports, logistics, local marketing or staff, an Italian VAT position may allow you to recover it through Italian returns, subject to the normal deduction rules. Without one, recovery follows the refund route, with its own conditions and timing.

Second, customer and platform requirements. Italian business customers, public bodies and marketplaces may require an Italian VAT number for their vendor records. That is a commercial constraint: it does not change the reverse-charge treatment of the B2B sale.

Third, B2C sales from the same stock. A consumer cannot reverse charge. If the same warehouse serves both business and consumer customers, the consumer leg generally forces an Italian VAT position — unless you are established outside the EU and a marketplace is the deemed supplier, as explained below.

Fourth, an Italian permanent establishment. If the sale is made through an Italian structure that actually intervenes, article 17(4) disapplies reverse charge and the supply is made by an Italian-established business.

There is also a practical customs point. Where you are the importer of record, customs and logistics providers may require an Italian VAT position before they will clear the goods or apply a deferred import-VAT arrangement. That is an operational requirement rather than a rule of the VAT decree, but it arrives earlier than most companies expect.

The marketplace overlay

Article 2-bis of Presidential Decree 633/1972 treats the operator of an electronic interface as the supplier in two situations. First, for intra-EU distance sales of goods and for domestic B2C supplies of goods made in the same Member State, but only where the underlying seller is not established in the EU. Second, for distance sales of imported goods in consignments up to EUR 150, irrespective of where the seller is established. The same provision treats the platform as having received and resold the goods. It does not rewrite the rest of the chain.

For a non-EU seller with Italian stock selling through a marketplace, the first situation can move the consumer-facing VAT to the platform. If you are established in the EU, the platform is not the deemed supplier for your intra-EU distance sales or domestic B2C supplies: you remain responsible for the VAT, even if the sale is facilitated by a marketplace. The import limb is different and can apply irrespective of your establishment. In every case, your own supply to the platform is a separate step, the platform's terms determine who bears import VAT and returns, and the deemed-supplier rule applies only to the listed supplies. Map the chain before assuming that the platform has removed your Italian position.

B2C sales from Italian stock: the consumer cannot self-assess

A private customer cannot integrate an invoice or issue a self-invoice. If you sell goods located in Italy directly to an Italian consumer, you must charge Italian VAT at the applicable rate: 22% as the standard rate, or 10%, 5% or 4% for the goods listed in the reduced-rate tables. The Agenzia's general VAT page confirms the four rates.

That means an Italian VAT position — direct identification under article 35-ter or a fiscal representative under article 17(3) — plus Italian invoicing and returns. The mechanics of obtaining the number are covered in our guide to getting an Italian VAT number, the timing in how long VAT registration takes, and representation in the fiscal representative guide. This article does not repeat them.

Two qualifications matter. First, if you are established outside the EU and the sale is made through a marketplace that is the deemed supplier under article 2-bis, the platform accounts for the VAT on the consumer sale, and your position depends on the upstream supply and the contract. The deemed supplier can declare the resulting domestic supply through the Union OSS, so an Italian VAT number is not the only possible route for that leg. Second, goods already in Italy are not "distance sales" in the technical sense, because article 38-bis(1) of Decree-Law 331/1993 requires dispatch from one Member State to another. You cannot solve your own direct Italian-stock B2C sale by using OSS; the deemed-supplier platform is in a different position.

Distance sales and imports: the thresholds in practice

The table below separates the cases that are often merged into one.

Seller established in	Goods dispatched from	Customer	Result
One EU Member State only	That Member State	Italian consumer	Italian VAT if the EU-wide value of intra-EU distance sales of goods and B2C TBE services exceeds EUR 10,000 in the current year or exceeded it in the previous year; otherwise VAT in the Member State of dispatch, unless the supplier opts for destination treatment
Established in one Member State and also has a fixed establishment in another	Either Member State	Italian consumer	The single-establishment condition for the EUR 10,000 threshold is not met; destination rules apply
Established outside the EU, with one or more fixed establishments in the EU	An EU Member State	Italian consumer	The EUR 10,000 threshold is not available; intra-EU destination rules apply. Imported goods follow articles 32-33 separately
Outside the EU	An EU warehouse in another Member State	Italian consumer	Italian VAT from the first sale; Union OSS where eligible, otherwise Italian registration
Outside the EU	An Italian warehouse	Italian consumer	Italian VAT from the first sale; Italian registration, unless a marketplace is the deemed supplier
Outside the EU	Outside the EU	Italian consumer, eligible non-excise goods in a consignment up to EUR 150	Italian VAT through IOSS, or VAT collected at import if IOSS is not used
Outside the EU	Outside the EU	Italian consumer, consignment above EUR 150	VAT collected at import; IOSS does not apply

The threshold is a simplification, not an exemption. Once it is exceeded, the destination rule applies to the sales concerned, and the supplier of goods already in the EU either registers in Italy or uses OSS. OSS is optional, but it replaces multiple registrations with one return; the Agenzia's OSS pages set out the Union, non-Union and import schemes.

Two timing points are worth building into your controls. The threshold is tested against the previous and the current calendar year, so a strong December can change the following January. And the calculation is EU-wide, so sales to Germany, Spain and Italy all count towards the same EUR 10,000.

Building a stock model: four questions

Own stock moved from another EU country

Moving your own goods from another Member State to an Italian warehouse is treated as an intra-Community acquisition in Italy. Article 38(3)(b) of Decree-Law 331/1993 includes within intra-Community acquisitions the introduction into Italy, by or on behalf of a taxable person, of goods coming from another Member State. The transfer is also a deemed intra-Community supply in the country of dispatch. The practical result is an Italian VAT registration before the goods arrive, unless a simplification applies.

Call-off stock

The call-off stock simplification in article 41-bis of Decree-Law 331/1993, which implements article 17a of the VAT Directive, suspends that result where the supplier transfers goods to Italy for a known customer. The conditions are cumulative: the customer must be a taxable person identified for VAT in Italy and known from the start of the transport; the supplier must not be established or have a permanent establishment in Italy; the goods must be dispatched by the supplier or by a third party on its behalf; and the customer must acquire ownership within 12 months of arrival. The supplier keeps a register and reports the transfer in its intra-EU listing.

If a condition fails, or the 12 months expire without the transfer of ownership, the transfer is treated as a supply and acquisition at that point. That normally means an Italian VAT registration and a regularisation. The Agenzia's answer 271/2023 confirms that the regime is confined to the relationship between the supplier and the designated customer, and cannot be stretched to a separate onward sale.

Third-country imports

If you import goods from outside the EU and hold them in Italy, you are in a different regime from the EU stock transfer. There is no intra-Community acquisition; there is an import, with import VAT and customs duties. The commercial question is who acts as importer of record. If it is your Italian customer, the sale may occur before the goods enter Italy and may sit outside the Italian place-of-supply rules, with the customer importing. If it is you, the goods become Italian-located stock after import, and the subsequent sales follow the rules above. The importer choice should be made with the customs representative, not reconstructed after the first shipment.

Is a warehouse a fixed establishment?

Not automatically. A third-party logistics warehouse gives you space, not necessarily a permanent establishment for VAT. The test in article 53 of Regulation 282/2011 is permanence plus adequate human and technical resources, and the establishment must intervene in the supply. The Agenzia's answer 57/2023 applies that test and rejects the idea that administrative support or marketing alone is enough. A warehouse operated by an unrelated logistics provider, with no staff or decision-making of yours in Italy, is a different case from an Italian branch with employees negotiating sales.

That distinction matters twice. For VAT, an intervening Italian establishment displaces reverse charge. For income tax, a permanent establishment is a separate question under article 162 of the Italian income tax code and the applicable treaty; a VAT registration does not create one, and a warehouse does not automatically create the other. Our guide to branch versus subsidiary covers the corporate analysis.

Where Italian VAT is not due

Not every cross-border sale fits one of the taxable patterns above. Four categories are often confused, and they have different consequences.

Category	Example	Consequence
Outside the scope of Italian VAT	B2C consulting by a non-EU supplier with no Italian establishment; goods outside Italy at the time of sale	No Italian VAT, no Italian return, no reverse charge
Non-taxable (export or intra-EU supply)	Goods exported outside the EU under article 8; goods dispatched to another Member State under article 138 of the Directive	No Italian VAT, but evidence and listing obligations; an Italian VAT position may be needed to issue the export invoice
Exempt	Financial, insurance, healthcare or education services within article 10	No VAT is charged; the territorial analysis still has to be done
Cross-border SME scheme	A natural person established in another EU Member State, within the EU and Italian thresholds	No Italian VAT on covered supplies, subject to the EX identification

The distinction between "outside the scope" and "non-taxable" is not cosmetic. An out-of-scope invoice should not cite an exemption article, and a non-taxable export needs the customs evidence. A wrongly labelled invoice can survive an accounting review and still fail an audit.

The small-business exclusion is narrower than "EU"

The cross-border SME scheme, introduced in Italy by Legislative Decree 180/2024 and explained in Circular 13/E/2025, allows a small business established in another EU Member State to apply the Italian exemption to its Italian-taxable supplies. It does not apply the home-country exemption, and the business does not need to be in a domestic SME regime at home: the Agenzia's press release of 17 December 2025 states that there is no link between the national and cross-border regimes and that a business may use either or both. The conditions are an EU-wide turnover of no more than EUR 100,000 and an Italian turnover of no more than EUR 85,000, a prior notification in the Member State of establishment, and an "EX" identification. The Agenzia's access page summarises the conditions.

It is not a general EU small-business passport. The Italian rules admit only natural persons who meet the access conditions of the Italian flat-rate regime, and the scheme is expressly closed to businesses established outside the EU. A German GmbH or a UK Ltd cannot rely on it. A sole trader or professional who qualifies may, and the Italian customer should verify the EX number before treating the invoice as exempt.

What registration does and does not change

Registration changes your own compliance position, not who owes the VAT on a B2B sale. You file Italian returns, recover input VAT and deal with Intrastat; if you are an Italian-established business, invoices to Italian customers go through the Sistema di Interscambio. A non-resident without an Italian permanent establishment remains outside the e-invoicing obligation even if identified or represented, and its B2B sales to Italian taxable persons remain reverse-charge transactions: the customer integrates the invoice or self-invoices, and you must not charge Italian VAT on them. Registration is what makes direct B2C sales from Italian stock workable, and it supports import and other domestic flows.

Registration also affects cash flow. For B2C customers VAT is a real price increase and has to be built into the commercial model; for B2B customers the tax remains neutral because the customer self-assesses. A registration obtained for B2C stock sales does not absorb the B2B flows from the same stock.

The route to registration is either direct identification under article 35-ter or a fiscal representative under article 17(3). The choice depends on where you are established and whether a mutual-assistance instrument applies. The fiscal representative guide sets out the appointment formalities and joint liability; the VAT number guide covers the forms.

Six mistakes that cost money

1. Treating an Italian customer as a reason to register. A B2B service customer usually self-assesses. Registration is driven by your supply, not by the customer's address.
2. Applying reverse charge to every goods sale. Reverse charge under article 17(2) applies to a non-resident B2B supplier without an Italian permanent establishment, including where the supplier is identified or represented; it does not apply to a consumer sale, or where the supply is made through an Italian permanent establishment.
3. Counting only Italian sales towards EUR 10,000. The threshold is EU-wide and covers intra-EU distance sales of goods plus telecom, broadcasting and electronic services, not all turnover.
4. Assuming the threshold is available outside the EU. It is conditioned on establishment in a single Member State. A US or UK seller shipping from outside the EU is in the import regime; one shipping from EU stock should assume Italian VAT from the first sale.
5. Assuming OSS can never cover goods already in Italy. For your own direct sale from Italian stock, OSS is not available: the supply is domestic and requires Italian registration. But a platform that is the deemed supplier under article 2-bis can declare the resulting domestic B2C supply through the Union OSS, including where the underlying seller is outside the EU. Distinguish your direct sale from the deemed-supplier sale.
6. Treating an invoice without VAT as automatically correct. "Outside the scope", "non-taxable" and "reverse charge" are different labels with different evidence requirements. The customer's TD17 or TD19 does not cure a misdescribed supply.

What to prepare before the first Italian sale

A workable file has six items: the customer's status and VAT identification; the place where the goods are at the time of supply and who transports them; the correct invoice wording and legal reference; the transport or export evidence; the reporting route (TD17 or TD19 for the customer, Intrastat or VIES where relevant); and a decision on registration that records why it was or was not taken. The tax analysis is shorter than the paper trail, but the paper trail is what survives an audit.

If the answer is still uncertain, the question to ask is not "do we need a VAT number?" but "which supply are we making, where is it taxed, and who is the debtor?" Once those three are settled, the registration question usually answers itself.

Sources

• Presidential Decree 633/1972, articles 7-bis, 7-ter, 7-quater, 7-quinquies, 7-octies, 8, 10, 17, 35-ter (consolidated text).
• Decree-Law 331/1993, articles 38, 38-bis, 41 and 41-bis.
• Directive 2006/112/EC, consolidated text, in particular articles 32, 33, 44, 45, 53, 58, 59c, 138, 17a and 192 bis.
• Customs implementing regulation, article 221(4), OJ L 2026/1200.
• Implementing Regulation (EU) 282/2011, articles 19 and 53.
• Agenzia delle Entrate, guide to electronic invoicing and the esterometro, version 1.10, April 2025.
• Agenzia delle Entrate, OSS guidance and OSS FAQ.
• Agenzia delle Entrate, IOSS guidance.
• Agenzia delle Entrate, Resolution 21/E/2015 and Answer 114/2023 on reverse charge and Italian identification.
• Agenzia delle Entrate, Answer 51/2023 on the deemed-supplier rule and EU-established sellers.
• European Commission, Explanatory Notes on the VAT e-commerce rules, July 2026, section 2.1.3.
• Agenzia delle Entrate, Answer 94/2026 and Fisco Oggi, 1 April 2026 on B2B event services.
• Agenzia delle Entrate, press release 17 December 2025 on the cross-border SME scheme.
• European Commission, OSS guidance and Register to OSS.
• Agenzia delle Entrate, cross-border SME scheme access page and Circular 13/E/2025.
• Agenzia delle Entrate, general VAT rules and rates.
• European Commission, place of taxation.