Italy: UK VAT groups not recognized beginning 2021

A ruling which states that effects of UK VAT groups are not recognized for Italian VAT purposes beginning 1 January 2021

UK VAT groups not recognized beginning 2021

The tax authority on 9 May 2023 published Ruling no. 314/2023, which states that the effects of UK value added tax (VAT) groups are not recognized for Italian VAT purposes beginning 1 January 2021.

This ruling reverses the tax authority’s previous position, expressed in Ruling no. 756/2021, which stated that UK VAT groups were still recognized post-Brexit. 


The VAT grouping provision in Italian VAT law Article 11 of EU Directive 2006/112/EC lays the foundation for the VAT grouping provisions introduced into the national legislation of EU Member States. Italian VAT grouping provisions have implemented the principles laid down by the ECJ Skandia and Danske Bank cases (C-7/13 and C-812/19), according to which head-office-to-branch charges are no longer disregarded for VAT purposes when the head office or the branch belongs to a VAT group in Italy or in another EU jurisdiction.

Read a May 2023 report [PDF 276 KB] prepared by the KPMG member firm in Italy


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