Italy: Annual contribution applicable to digital, media, and platform activities

Italy introduced, as part of its 2026 Budget Law, a contribution to AGCOM (the National Authority for Communications), which applies to a broad range of digital, media, platform, and intermediary activities, including non-Italian businesses generating in-scope revenues connected to Italy.

The contribution is expressly qualified as a tax obligation under Italian law and is payable to AGCOM by March 31, 2026, based on revenues reported in the most recently approved financial statements.

Below is a high-level summary of the regime.

Activities in scope

The AGCOM contribution is activity-based. Entities (including non-Italian residents) are required to pay the contribution if they derive revenues from activities identified by law to the extent those revenues are realized in Italy, even where such revenues are booked in the financial statements of a foreign entity.

In-scope activities are:

• Electronic communications: Provision, management, and availability of electronic communications networks and digital infrastructures; network operator activities (including television); electronic communications services, including interactive and conditional access services; and use of numbering resources
• Postal services: Postal services subject to individual licenses or general authorizations, including express courier and parcel delivery services
• Audiovisual, media, and advertising services: Audiovisual and radio media services; sound broadcasting; video sharing platform services; content creation, production, or organization on video sharing platforms; production or distribution of audiovisual and radio programs (including formats); cinematographic and musical works; and advertising and sponsorship activities, including online
• Publishing and information society services: Publishing activities (including electronic publishing); information society services enabling online use of journalistic publications; press agencies; media monitoring; and press review services
• Digital and intermediary services: Digital services, including those provided through e-commerce websites, and intermediary services within the meaning of Article 3, letters g), i), and j) of Regulation (EU) 2022/2065 (Digital Services Act), to the extent not already covered by the categories above

When an entity operates across multiple in-scope sectors, revenues must be segmented by activity, and the contribution must be calculated separately for each sector using the applicable per mille rate.

Tax base

The contribution is calculated on “revenues realized in the national territory,” as reflected in the most recently approved financial statements, or, for entities not required to prepare financial statements, the corresponding items in other accounting records. Revenues may be in scope even if booked in the accounts of non-Italian entities, provided they are attributable to Italian activity.

Sourcing

AGCOM guidance does not prescribe a specific methodology for determining when revenues are realized in Italy. In practice, taxpayers are expected to apply a reasonable, consistent, and auditable allocation methodology, aligned with their accounting and commercial data, to identify Italian-sourced revenues. Examples include billing address, customer location, and place of consumption. Supporting documentation should be retained in case of review.

Rates and exemptions

For most digital services, e-commerce, and platform activities, the applicable rate for 2026 is 2 per mille (2‰). Different per mille rates apply for electronic communications and postal services. A de minimis exemption applies where the calculated contribution does not exceed €100 (payment not due, though filing obligations may still apply). There is no credit or offset against value added tax (VAT), digital services tax (DST), or other indirect taxes.

Compliance, filing, and payment

The liable entity is generally the entity that books the Italian-sourced revenue. Where multiple group entities earn Italian-sourced revenues, each entity must file and compute the contribution independently on its own revenue base. The contribution must be filed and paid by March 31, 2026. Compliance requires mandatory electronic filing through the AGCOM portal (Impresa in un Giorno), with payment made via PagoPA or by bank transfer using the payment reference generated by the system.

Penalties and enforcement

Where payment is made late, statutory interest applies for the period of delay. In cases of non-payment, AGCOM may refer the amount due to the Italian Revenue Agency for collection. Current guidance does not provide for extensions of the deadline.

Failure to submit the form on time (i.e., by March 31, 2026) could trigger a penalty capped at €130,000. This penalty may be reduced if the form is submitted at a later date, in addition to statutory interest for late payment.

KPMG observation

While the contribution is not a VAT, it is relevant for many of the same digital and platform business models typically reviewed by VAT teams, particularly in the context of digital services, marketplaces, software as a service (SaaS), online advertising, and platform intermediation. The application to Italian-sourced revenues, even if booked by non-Italian entities, means that a number of multinational groups may be within scope even in the absence of an Italian establishment.

The key challenges are expected to relate to identifying and allocating Italian-sourced revenues, especially for platform and intermediation models, given the lack of prescriptive sourcing rules. In addition, groups operating across multiple in-scope activities should be mindful that the contribution applies on a sector-by-sector basis, requiring revenue segmentation and the application of different per mille rates where relevant. Given the fixed March 31, 2026, deadline and the potential for enforcement through the Italian Revenue Agency, affected businesses may wish to assess exposure early and assess whether any allocation approach adopted is reasonable, consistent, and supportable.

For more information, contact a KPMG tax professional:

Philippe Stephanny | philippestephanny@kpmg.com

Chinedu Nwachukwu | chinedunwachukwu@kpmg.com

Davide Morabito | dmorabito@kpmg.it

Francesco Marconi | fmarconi@kpmg.it