Italy Tax Agency Issues Circular Clarifying VAT Treatment of Personnel Secondments, Loans

The Italian Revenue Agency May 16 issued Circular No. 5/E, on repeal of the VAT exemption for loans or secondment of personnel, following legislative changes effective Jan. 1. Topics covered include: 1) conditions subjecting secondment or lending of personnel to VAT, including if payment equals cost reimbursement; 2) applicability of the repeal to contracts signed or renewed from Jan. 1, including special transitional rules; 3) guidance on the subjective, objective, and territorial scope of VAT, to clarify exemption eligibility; and 4) special considerations for reimbursements between co-employers. [Italy, Revenue Agency, 05/16/25]

Reference:
View Circular No. 5/E. View Index. ...