Italy Tax Agency Clarifies VAT Treatment of Personnel Secondments, Loans

The Italian Revenue Agency Feb. 18 issued Answer No. 38/2025, clarifying the VAT treatment of secondments and loans of personnel between two companies. Taxpayer A, an in-house company, provided design, development, and management of information technology (IT) systems for its members. Taxpayer B, an instrumental body, managed health and social health activities. Taxpayer B required temporary strengthening of its technical-administrative sector, prompting a request for A to second some employees with the required professional skills. It was argued that the reimbursement of costs incurred by A for the seconded personnel shouldn’t be subject to VAT, because it merely covered actual ...