Italy Tightens VAT Guarantee Rules for Non-EU Businesses Ahead of June Deadline

Italy has introduced a new regulatory requirement for non-EU businesses seeking VAT registration and inclusion in the EU’s VAT Information Exchange System (VIES), mandating a financial guarantee of €50,000. The measure, which must be fulfilled by 13 June 2025, is part of the government’s effort to tighten controls on cross-border tax compliance and ensure the reliability of intra-EU trade.

Purpose of the New Rule

The €50,000 guarantee — which can be presented as a bank guarantee or insurance bond — is intended to mitigate VAT fraud risks and promote greater fiscal responsibility among foreign businesses operating in Italy without a local establishment. According to Italy’s Revenue Agency, the measure will apply to non-EU companies that either register directly for Italian VAT or appoint a tax representative within the country.

“This is about building trust and traceability within the EU’s single market,” the Revenue Agency said in a statement. “We want to make sure that companies operating from outside the EU are just as accountable as those based within.”

Who Is Affected?

The regulation primarily impacts non-EU businesses involved in:

• E-commerce sales to Italian customers
• B2B transactions with EU clients
• Participation in intra-community acquisitions
• Provision of digital services to EU consumers

Failure to comply by the 13 June deadline may result in the rejection of VAT registration requests or removal from the VIES database, which could severely restrict a company’s ability to conduct B2B transactions within the EU.

Reactions from the Business Community

The announcement has drawn mixed reactions. While some stakeholders see it as a necessary step to prevent fraud, others — especially smaller businesses and startups — are concerned about the financial burden and administrative complexity.

“This may deter some companies from entering the Italian market altogether,” said Luca Venturi, a tax advisor based in Milan. “But for those who are serious about doing business in the EU, it’s a clear signal that compliance is non-negotiable.”

Broader EU Context

Italy's move aligns with broader EU efforts to modernize VAT collection and close the so-called "VAT gap" — the difference between expected and collected VAT revenues. Similar initiatives are under consideration in other member states as the European Commission works toward a unified digital VAT system under its "VAT in the Digital Age" (ViDA) proposal.

Key Takeaways:

• Non-EU businesses must provide a €50,000 guarantee for VAT registration in Italy.
• The rule also applies to VIES listing and must be met by 13 June 2025.
• Non-compliance could hinder access to EU markets and tax systems.
• Businesses are urged to act promptly to avoid disruption.

For further information or assistance with compliance, companies are advised to consult their local tax advisors or contact Italy’s Revenue Agency directly.

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