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New Compliance Framework for Fiscal Representation in Italy
This new framework strengthens fiscal security in Italy and ensures that only fully compliant and financially solid professionals can act as Authorized VAT Fiscal Representatives, protecting both international businesses and the Italian tax system.
In 2025, the Italian Revenue Agency introduced a new compliance framework governing Fiscal Representation (VAT Representative) in Italy.
Key rules include:
Mandatory Requirements (Art. 17 DPR 633/72)
Only professionals meeting strict integrity and tax compliance standards can act as fiscal representatives. A formal declaration and supporting documents must be filed with the local Revenue Office.
Financial Guarantee Obligation
Representatives must provide a bank guarantee or insurance bond, the amount of which depends on the number of clients represented (from €30,000 up to €2,000,000 for over 1,000 clients). The guarantee must remain valid for at least 48 months.
Additional Guarantee for VIES Registration (Art. 35 DPR 633/72)
Non-EU companies wishing to operate in the EU via an Italian fiscal representative must provide an additional guarantee of €50,000 to be included in the VIES database (enabling intra-EU transactions). This guarantee is valid for at least 36 months.
Formal Appointment of the Representative
The appointment must be documented through notarized deeds, registered contracts, or apostilled powers of attorney, in compliance with the Hague Convention. The representative is jointly liable with the non-resident company for all VAT obligations.