Application and Commencement
It reorganises and integrates all existing VAT rules (DPR 633/1972) for domestic VAT and Decree-Law No. 331/1993 for intra-EU transactions) into a single legal text.
It applies to all the persons who are paying VAT under current VAT mechanism. It will come into force w.e.f. January 1, 2027. Until that date, existing VAT laws (DPR 633/1972, DL 331/1993, and related VAT legislative acts) continue to apply normally.
Key Changes
The consolidated code does not fundamentally change the substance of VAT rules e.g. taxable events, rates structure (22%, reduced rates, etc.), eligibility for deductibility, etc.
But repeals the existing standalone provisions of the VAT regulation (DPR 633/1972), DL 331/1993 and many scattered amendments. Most provisions are copied from the old laws into a new structured, thematic framework.
Unified organisation: domestic, intra-EU and miscellaneous VAT regimes are integrated — eliminating the need to cross-reference multiple separate texts.
New Rules Integrated
Territoriality and digital services: updated rules on where VAT applies for digital and streaming services.
Franchise regime for small cross-border traders, updated exemptions for certain professional services (e.g., some aesthetic procedures).
Incorporation of electronic invoicing, electronic data records and communications, reflecting modern VAT administration.
Rules on export documentation: proof of export now requires evidence of customs exit (e.g., doganale) and no longer relies on older “bolla di accompagnamento” practices.
|
Subject Matter |
Old Provision (DPR 633/1972 / DL 331/1993) |
New Consolidated Code (D.Lgs. 10/2026) |
Nature of Change |
|---|---|---|---|
|
Taxable transactions (supplies of goods & services) |
Art. 1–3 DPR 633/1972 |
Title I – Arts. 1–7 |
Substantively unchanged; reorganised for clarity |
|
Territoriality – goods |
Arts. 7-bis to 7-sexies DPR 633/1972 |
Title II – Territoriality provisions |
Structure aligned more clearly with EU directive |
|
Territoriality – services |
Arts. 7-ter to 7-septies DPR 633/1972 |
Title II – Services chapter |
Language updated; principles unchanged |
|
Intra-EU acquisitions |
DL 331/1993, Arts. 38–47 |
Integrated into Title III |
Previously separate law now fully integrated |
|
Exports (non-taxable transactions) |
Art. 8 DPR 633/1972 |
Title IV – Non-taxable operations |
Documentation rules modernised |
|
Exempt transactions |
Art. 10 DPR 633/1972 |
Title V – Exemptions |
Same categories; clearer structure |
|
VAT rates (22%, 10%, 5%, 4%) |
Arts. 16 & Table A DPR 633/1972 |
Dedicated Title + Annex Tables |
Tables consolidated; rates unchanged |
|
VAT deduction (input VAT) |
Arts. 19–19-bis DPR 633/1972 |
Title VI – Deduction system |
Logical restructuring; no major substantive change |
|
Pro-rata deduction |
Art. 19-bis DPR 633/1972 |
Included in Deduction chapter |
Clarified computational rules |
|
VAT groups |
Art. 70-bis et seq. DPR 633/1972 |
Separate Title on VAT grouping |
Reordered; regime maintained |
|
Invoicing requirements |
Arts. 21–25 DPR 633/1972 |
Title VII – Invoicing & records |
Electronic invoicing fully embedded |
|
Registration & bookkeeping |
Arts. 23–39 DPR 633/1972 |
Accounting chapter |
Modernised references to digital registers |
|
VAT returns & payments |
Arts. 27–30 DPR 633/1972 |
Final Titles – Compliance & settlement |
No structural change; harmonised |
|
Refunds |
Art. 30 DPR 633/1972 |
Refund chapter |
Same entitlement; clarified procedures |
|
Special regimes (margin scheme, agriculture, travel agents) |
Arts. 34, 36, 74-ter DPR 633/1972 |
Dedicated Special Regimes Title |
Better classification; no policy shift |
|
Small business regime |
Art. 32-bis & related provisions |
Integrated in Special Regimes Title |
Harmonised with EU SME rules |
Key Documents for Reference:
Existing/Old Law: Decree No. 633/1972- Establishment and Regulation of Value Added Tax
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