VAT registration in Italy and fiscal representation
A foreign business with Italian VAT obligations but no Italian permanent establishment chooses between direct identification and an Italian fiscal representative. The choice decides who files, who deals with the Revenue Agency and who carries the exposure.
Published by Proclama S.T.P. S.p.A. · Last updated October 2026
What we do
We establish whether an Italian VAT position is needed at all
Many B2B services to an Italian VAT-registered customer are handled by the customer under the reverse charge, and some intra-EU transactions follow their own reporting. The transaction is analysed before a registration is opened.
Direct VAT identification under article 35-ter
For a business established in another EU member state, and for non-EU businesses established in a country with an applicable mutual assistance instrument, we prepare form ANR/3 and the evidence of VAT-taxable status, and file with the competent office.
Appointment as fiscal representative
For a business that cannot use direct identification, we act as its Italian fiscal representative: appointment in the prescribed form, start-of-activity declaration and the ongoing VAT compliance that follows.
Electronic invoicing and foreign supplier documents
We handle the documents that bring foreign purchases into the Italian system — TD17 for services, TD18 for intra-EU goods, TD19 for goods under article 17(2) of the VAT decree — and the transmission deadlines that go with them.
VAT returns, registers and payments
Periodic settlements, the annual VAT return, the registers and the payment of the VAT due, with the credit and refund procedures where they apply.
OSS, kept separate from the Italian registration
The One Stop Shop schemes are optional registrations, separate from the Italian VAT number, that centralise EU consumer-facing VAT in one member state. Where they apply we keep the two positions distinct in the books.
Which route applies
| Where the business is established | Usual route for Italian VAT | Formalities |
|---|---|---|
| EU member state | Direct identification under article 35-ter, or a representative as the alternative | Form ANR/3, with evidence of the VAT-taxable status in the home country |
| Non-EU with a mutual assistance instrument | Direct identification may be available | Subject to the instrument and the Revenue Agency procedure; Norway is the established example (Resolution 44/E/2020) |
| Non-EU without such an instrument | Fiscal representative generally mandatory when registration is needed and there is no Italian permanent establishment | Appointment in the prescribed form plus the start-of-activity declaration |
What the representative actually does
Depending on the transactions and the engagement, the work covers registering or updating the VAT position, issuing or receiving Italian VAT invoices and transmitting the required electronic documents, keeping the VAT registers and the transaction evidence, preparing the periodic settlements and the annual return, paying the VAT and handling credits or refunds, filing Intrastat declarations where relevant, and answering information requests or audits within the mandate.
“Light” and “full” representation
The two labels describe practice, not two legal statuses created by article 17(3). A limited regime exists in a narrow situation: where the non-resident carries out only non-taxable, exempt or out-of-scope operations, article 44(3) of Decree-Law 331/1993 limits the representative's obligations principally to invoicing and Intrastat reporting. It does not cover a normal taxable operation, and the simplified treatment ends at the first ordinary operation requiring VAT payment.
If the appointment is missing
A business that needed representation and did not appoint one risks being unable to issue compliant invoices, account for VAT, exercise deduction or refund rights, or support intra-EU reporting. Failure to submit a required VAT start-of-activity or change declaration can attract an administrative penalty of €500 to €2,000, and other failures carry separate penalties.
For the wider picture, read how to get an Italian VAT number and fiscal code as a non-resident and Italian e-invoicing (SDI) for foreign-owned companies.
How it works
- 1
Transaction analysis
We look at what you sell, to whom and from where, and at whether an Italian permanent establishment already carries out the operation.
- 2
Route decision
Direct identification or representation, with the reasons written down: the two mechanisms are alternatives, not two VAT numbers to run in parallel.
- 3
Registration and appointment
The form and the appointment documents are filed with the competent office; the VAT position starts before the first territorially relevant transaction.
- 4
Operating cycle
Invoices, registers, settlements, annual return and payments, with the deadline calendar for received foreign documents.
What it costs
By quote, itemised by activity.
Italian law does not set a standard fee for fiscal representation. The quote depends on the volume of transactions and on the work included — registration and appointment, returns, invoicing, Intrastat, registers, correspondence and audit assistance — and it separates the one-off part from the recurring part.
The written proposal identifies the registration work, the recurring compliance, the transaction volumes and any separate guarantee or security costs. The joint liability and the guarantees involved are part of why an address-only offer should be examined carefully.
- Registration of the VAT position and the appointment documents
- Periodic settlements, registers and the annual VAT return
- Payments, credits and refund procedures within the mandate
- TD17, TD18 and TD19 transmissions for foreign supplier invoices
- Intrastat declarations where relevant
Any bank guarantee, insurance or other security required by the rules is a separate cost, as are customs work and audit assistance beyond the mandate.
What you need from us
Nothing on this list is filed without your instruction or signature. Where a step needs a document issued on your side, we tell you before the deadline, not after it.
What we need from you
- Certificate of incorporation and evidence of your VAT-taxable status in the country of establishment
- Description of the transactions with Italy: goods or services, business or consumer customers, volumes
- The Italian customers' tax data, and the channel on which you want to receive electronic invoices
- Invoices received from foreign suppliers, as they arrive
- The mandate in the form required for the route chosen
What you get from us
- A written assessment of the route and its consequences
- The registration file and the appointment documents
- VAT settlements, annual return and payments within the mandate
- The TD17, TD18 and TD19 transmissions for foreign supplier invoices
- A representative who answers in English and signs the filings
Frequently asked questions
Do I need an Italian VAT number if I only sell to Italian businesses?
Not necessarily. Many B2B services supplied to an Italian VAT-registered customer are handled by that customer under the reverse charge, and some intra-EU transactions follow their own reporting. Registration is needed when the foreign business itself has to account for Italian VAT — for example selling goods from stock located in Italy, making domestic business-to-consumer supplies, or carrying out other Italian-territory transactions. Each transaction has to be analysed first.
What is the difference between direct identification and a fiscal representative?
Under article 17(3) of Presidential Decree 633/1972 a non-resident without an Italian permanent establishment exercises VAT rights and obligations either directly, through identification under article 35-ter, or through an Italian-resident representative appointed in the prescribed form. With direct identification the foreign business files and exercises its rights itself; with representation an Italian party stands inside the compliance chain and is jointly liable for the VAT.
Can my EU company choose a fiscal representative instead of direct identification?
Yes. Direct identification is generally available to an EU business, but representation can be used as the alternative route. They are alternative VAT mechanisms and have to be coordinated if the business changes route, including in the annual return.
How is a fiscal representative appointed?
The appointment must be evidenced by a public deed, a registered private instrument or a letter recorded in the appropriate register at the Agenzia delle Entrate office competent for the representative's tax domicile. The VAT start-of-activity declaration is filed with it — form AA7/10 for entities and other non-individual taxpayers, form AA9/12 for individuals and self-employed persons — at the provincial office competent for the representative's tax domicile.
What does joint liability mean in practice?
Article 17(3) makes the representative jointly liable with the foreign business for obligations arising under Italian VAT rules. That is why onboarding checks, data cut-offs and approval controls exist, and why an address-only offer at a suspiciously low price deserves a careful look. The foreign business remains responsible for giving complete and timely data.
How do I record an invoice received from a foreign supplier?
The Italian company integrates the supplier's invoice or issues a self-invoice through the Sistema di Interscambio, using TD17 for services purchased abroad, TD18 for intra-EU purchases of goods, TD19 for goods purchased under article 17(2) of the VAT decree, or TD28 for a paper San Marino invoice carrying VAT. The transmission is due by the fifteenth day of the month following receipt of the document or the transaction.
Do I have to issue electronic invoices if I am only identified in Italy?
A non-resident business that holds only an Italian VAT position is not itself required to issue or receive electronic invoices, but its Italian suppliers must invoice it electronically, normally with the code 0000000 unless it gives them a specific channel. Its Italian VAT number can therefore receive invoices that are not readable without a channel or a delegate.
How much does fiscal representation cost?
There is no statutory price list: the fee is a commercial quote. It depends on the volume of transactions and on the work included — returns, invoicing, Intrastat, registers, correspondence and audits. We send an itemised quote that separates the one-off registration and appointment from the recurring work.
Read next
What is an Italian fiscal representative (and do you need one)?The full explanation: when representation is mandatory, how the appointment is formalised, what joint liability means and how to read a quote.
Check the route before the first invoice
Tell us where the company is established, what it sells into Italy and to whom. A chartered accountant reviews your request and replies in English with the route that applies and an itemised quote.