Italy VAT tax representative for non-EU sellers (rappresentante fiscale)

The short answer

Italy has no registration threshold in the texts read for a business outside the EU. A business with no establishment in Italy meets its Italian VAT duties either directly, by direct identification, or through a representative resident in Italy (DPR 633/1972 art. 17(3)). Direct identification is open only to a business operating in another EU state or in a country with a mutual-assistance instrument for indirect tax (art. 35-ter(5)). The Agency ruled in 2021 that the United Kingdom qualifies and in 2020 that Norway does; those are the only third countries named in the texts read. A business from any other country, the United States included, appoints a rappresentante fiscale, which answers jointly with it for its VAT (art. 17(3)). A business outside the EU and the EEA that uses a representative and wants to be in the VIES database also gives a guarantee with a ceiling of at least EUR 50,000, valid for at least 36 months (art. 35(7-quater); Ministry decree of 4 December 2024; Agency provision of 14 April 2025). The representative gives its own guarantee only once it acts for two or more businesses (Ministry decree of 9 December 2024).

Last checked: 6 October 2026
Country: Italy
EU rule: Fiscal representative for EU VAT: when a business outside the EU needs one, what it owes and who is liable

Italy requires a business from a country without a VAT mutual-assistance instrument to act through a fiscal representative resident in Italy, a rappresentante fiscale, which answers jointly with it for its VAT. Direct identification, the alternative, is open only to a business operating in another EU state or in a country with such an instrument. If yours is neither, you need the Italy fiscal representative (DPR 633/1972 art. 17(3), art. 35-ter(5)). A business outside the EU and the EEA that uses a representative and wants its number in the VIES database also gives a guarantee with a ceiling of at least EUR 50,000. The EU rules are in the fiscal representative guide. The other Italian rules are on the Italy page.

You register in Italy when your sale is Italian

A sale of goods is Italian when the goods are in Italy (art. 7-bis(1)). The Agency requires a non-resident that also sells to final consumers or to bodies without a VAT number to meet its VAT duties in Italy (Agenzia delle Entrate). The EU rule is in EU VAT registration.

Your case	Italian registration?
Stock in Italy, in your own warehouse or a fulfilment warehouse such as Amazon FBA, sold from your own shop to consumers in Italy	Yes. The goods are in Italy when sold (art. 7-bis(1)).
Your own stock moved into Italy from another EU country	Yes. It is an intra-EU acquisition in Italy (DL 331/1993 art. 38(3)(b)).
Stock in Italy, sold through a marketplace to consumers in Italy	Yes, unless the marketplace is established in Italy. This is this site’s reading of the provisions together; no Agency text says it. The marketplace is treated as buying the goods from you and selling them on (art. 2-bis(1)(a), (2)). Your supply to it is exempt (art. 10, third paragraph) and you keep the deduction (art. 19(3)(d-bis)). The invoicing and recording waiver of art. 36-bis leaves this supply out, and the invoice carries the note “operazione esente” (art. 21(6)(c)). A non-resident meets those duties under art. 17(3), so you need an Italian VAT number. If the marketplace is a taxable person established in Italy, art. 17(2) puts the duties on it as the buyer and you need none. Stock held in Italy usually forces registration anyway, through the intra-EU acquisition in the row above or through import.
Every customer in Italy is a VAT subject established in Italy	No. The customer meets the VAT duties on your sale (art. 17(2), Agenzia delle Entrate).
Stock in Italy, shipped to consumers in other EU countries	You may opt for the Union OSS in Italy. The option uses your Italian VAT number, so the registration comes first (art. 74-sexies(2), (3)). See VAT OSS.
Parcels of EUR 150 or less from outside the EU to EU consumers, with your IOSS registration in Italy	You identify for IOSS in Italy through one representative appointed for that scheme, unless you are established in a third country with an EU mutual-assistance agreement and ship from that country (art. 74-sexies.1(1)). See IOSS.
Only costs with Italian VAT and no Italian sales	No registration. Italy refunds the VAT on purchases and imports connected with your activity to a business established in a non-EU state, on condition of reciprocity (art. 38-ter(1), (2)).

No turnover threshold applies to a non-resident in the texts read. The EUR 10,000 distance-selling limit is for a seller established in one EU country, on VAT OSS.

A fiscal representative is the route unless a mutual-assistance instrument applies

A business with no establishment in Italy meets its VAT duties “direttamente, se identificati ai sensi dell’articolo 35-ter, ovvero tramite un loro rappresentante residente nel territorio dello Stato”: itself, if identified directly, or through a representative resident in Italy. The representative “risponde in solido con il rappresentato”, answering jointly with the business (art. 17(3)). Direct identification is limited to a business operating in another EU state, or in a third country with legal instruments on mutual assistance in indirect taxation like Directives 76/308/EEC and 77/799/EEC and Regulation (EEC) 218/92 (art. 35-ter(5), form ANR/3).

Your business is established in	Route
An EU or EEA country	Direct identification with form ANR/3, or a representative (Agenzia delle Entrate).
The United Kingdom	Direct identification is open, or a representative. The Agency reads the VAT protocol of the EU-UK agreement of 24 December 2020 as substantially similar to the EU instruments. A representative or an Italian VAT number held from before 1 January 2021 stays usable for domestic operations (Risoluzione 7/E).
Norway	Direct identification is open, or a representative. The Agency ruled that the VAT cooperation agreement signed by Norway and the EU on 1 August 2018 is fully analogous to the EU instruments and meets art. 35-ter(5) (Risoluzione 44/E of 28 July 2020).
Another country with a mutual-assistance instrument for indirect tax	Direct identification (art. 35-ter(5)). The Italian texts read name no country here other than the United Kingdom and Norway.
Any other country, the United States among them	A representative resident in Italy. No Italian text read names an instrument for the United States, so plan on this route. This is the one edge case in the table: the Agency pages read publish no country list.

Whichever route you take, you stay a non-resident for VAT purposes (Agenzia delle Entrate). The EU rule on what a tax representative is, and which other countries require one, is on fiscal representative.

What the representative must be

It is resident in Italy. Since D.Lgs. 13/2024 art. 4(1)(a), which added them to art. 17(3), it must also meet personal requirements and, once it acts for two or more businesses, give a guarantee (D.Lgs. 13/2024 art. 4, decree of 9 December 2024).

Personal requirements. The representative states in a declaration to the Agency that it has no conviction, even non-final, or plea sentence for financial crimes; no pending trial for financial crimes; no serious and repeated breach of social security or tax rules; and none of the conditions of art. 15(1) of Law 55/1990. A legal person’s legal representatives make the declaration (Agency provision of 17 April 2025, point 2).
A guarantee that grows with its clients. A representative for one business gives the declaration only. For more, the guarantee ceiling is at least the figure below, valid for at least 48 months from delivery, as State securities, a bank guarantee or an insurance policy. It is not renewed unless the representative moves to a higher band.

Businesses the representative acts for	Minimum guarantee ceiling
One	None. The declaration of the personal requirements is enough.
2 to 9	EUR 30,000
10 to 50	EUR 100,000
51 to 100	EUR 300,000
101 to 1,000	EUR 1,000,000
More than 1,000	EUR 2,000,000

The Agency’s verification service lists the representatives that declared the requirements and gave the guarantee where it is due (Agenzia delle Entrate, verification service). The Agency lists the decrees and provisions behind these requirements on its Normativa e prassi page. The appointment takes one of the forms that art. 17(3) takes from DPR 441/1997 art. 1(4): a public deed, a registered private agreement or a letter entered in a register at the Agency office for the representative’s tax domicile (Come registrarsi). No Italian text read sets a fee for a representative.

The EUR 50,000 guarantee is for the VIES database

A business outside the EU and the EEA that meets its VAT duties through a representative must give a guarantee to be included in VIES, the database of businesses that trade within the EU (art. 35(7-quater)). You state the wish to carry out intra-EU operations in the start-of-activity declaration, and that leads to VIES inclusion (art. 35(2)(e-bis), (7-bis)).

Point	What the decree and the Agency say
Amount	A ceiling (valore massimale minimo) of at least EUR 50,000. The decree speaks of a ceiling, not of a sum paid to the Agency. In the deposit form, the securities are held in a restricted deposit (deposito vincolato) (art. 1(2), Agency provision, point 2.5).
Form and addressee	A deposit of State securities or securities guaranteed by the State, a bank guarantee or an insurance policy, issued under art. 1 of Law 348/1982, in favour of the director of the Agency’s provincial directorate for the representative’s tax domicile. You or the representative deliver it there (art. 1(1), (2), (3), Agency provision, point 2.4).
How long	At least 36 months from delivery. After that it does not have to be renewed (art. 2).
When	A business that already holds a VAT number gives it before it asks for VIES. A business without a number gives it with the start-of-activity declaration that asks for VIES. Only from the date the directorate confirms it can you ask for VIES inclusion (Agency provision, points 2.1, 2.2, 2.8, 2.9).
A business already in VIES	It had sixty days from 14 April 2025 to give it. After that the Agency tells the representative by certified e-mail or registered letter that exclusion has started, and excludes the number after sixty more days if the guarantee is still missing (decree, art. 3, Agency provision, point 3).

Two other EUR 50,000 guarantees in art. 35 are not this one: paragraph 15-bis.2 concerns a VAT number the office closed under risk checks, and paragraph 15-ter(b) concerns named types of taxpayer (art. 35).

How you register, in order

Appoint a representative that qualifies, unless you identify directly. It is resident in Italy, has declared the personal requirements and, if it acts for more than one business, has given its guarantee (Agency provision of 17 April 2025, points 2 and 4.1 to 4.4).
Sign the appointment in a public deed, a registered private agreement or a letter entered in the register of the Agency office for the representative’s tax domicile (Agenzia delle Entrate).
File the start-of-activity declaration. Use form AA7/10 for a company and AA9/12 for a sole trader, with the appointment papers, only at the Agency’s Direzione Provinciale for the representative’s tax domicile (Agenzia delle Entrate, Come registrarsi). An e-commerce seller also gives its website address and the identity of its internet service provider (art. 35(2)(e)).
Ask for VIES and give the guarantee in the same step, if you will trade within the EU.
Tell your customers before your first Italian sale. The appointment must reach the other party before the operation (art. 17(3)). The law allows thirty days from the start of a business to file (art. 35(1)), so appoint before the sale.
Show the number on your website. The partita IVA goes on the declarations, on the home page of any website and on the other documents where it is required (art. 35(1)).

Direct identification, if you qualify, goes to the Agency’s operating centre in Pescara, by hand (also through a person you appoint for it) or by registered post. The post route carries a copy of an identity document and the certificate of VAT status in your home state, and counts as filed on the day it is posted (form ANR/3). The number it gives is marked as that of a non-resident identified in Italy. The declaration includes your undertaking to show your accounting records within the time the office sets (art. 35-ter(2)(e), (3)). A change in the declared data goes to the Agency within thirty days (art. 35-ter(4)); the ANR model is also the one for a change or the end of the activity.

You file and pay in Italy

With a representative, your duties are carried out through it (art. 17(3)).

Return	Due
Periodic VAT settlement, monthly	By the 16th of each month for the previous month, with the payment. If the amount is EUR 100 or less, it is paid with the next month’s, and by 16 December at the latest (DPR 100/1998 art. 1(1), (4)).
December advance, monthly payers	By 27 December, an advance on the December settlement. This page does not state the percentage: no primary text read settles the figure in force (L. 405/1990 art. 6(2)).
Annual VAT return	Electronically between 1 February and 30 April for the previous year, also with no taxable sales (DPR 322/1998 art. 8(1)).
Union OSS return, if you use it	Each quarter, by the end of the month after it, with the payment, nil returns included (art. 74-quinquies(6), (9), applied by art. 74-sexies(1), (4)). See VAT OSS.
IOSS return, if you use it	Each month, by the end of the next month, with the payment, also with no sales (art. 74-sexies.1(10), (14)). See IOSS.

OSS, IOSS and marketplaces: what Italy adds

The IOSS representative reports its own details and those of each seller it acts for (art. 74-sexies.1(4), (6)). It is a second appointment, separate from the VAT representative of this page. See IOSS and, for the Union OSS option, VAT OSS.

A marketplace keeps the records of the consumer sales it facilitates for ten years from 31 December of the year of the operation (art. 39). See EU VAT for online sellers.

What happens if you do nothing

The articles below are in force until 31 December 2026. From 1 January 2027 the same fines and offences, with the same amounts, are in the Testo unico delle sanzioni tributarie; the new numbers are in the last section.

If you	The consequence
Do not file a declaration of start or change of activity, or file one so incomplete or inaccurate that you, your places of business or your books cannot be identified	A fine of EUR 500 to 2,000. The same fine falls on an incomplete or inaccurate request or change notice for a non-Union OSS or IOSS registration. It is cut to one fifth of the minimum if you correct it within thirty days of the office’s invitation (D.Lgs. 471/1997 art. 5(6)).
Pay late	25 percent of each amount not paid, halved for a delay of up to ninety days. For up to fifteen days the halved penalty is further reduced to a fifteenth of it for each day of delay (art. 13(1)).
Do not file the annual VAT return	120 percent of the tax due for the period, at least EUR 250. EUR 250 to 2,000 where no tax is due (art. 5(1), (3)).
File a return that shows less tax than is due	70 percent of the extra tax, at least EUR 150 (art. 5(4)).
Omit a return with intent to evade more than EUR 50,000 of tax	Prison of two to five years. A return filed within ninety days of the deadline is not treated as omitted (D.Lgs. 74/2000 art. 5).
Do not pay VAT shown in the annual return, above EUR 250,000 for a tax period, by 31 December of the year after the return, and are not paying the debt in instalments	Prison of six months to two years. If an instalment plan lapses, the offence applies once the residual debt is above EUR 75,000 (art. 10-ter).
Were in VIES through a representative on 14 April 2025 and gave no guarantee in the two sixty-day periods	The Agency excludes your number from VIES (Agency provision of 14 April 2025, point 3).
Have a representative that was already working in April 2025 and gave neither declaration nor guarantee within sixty days of the 17 April 2025 provision and sixty more from the Agency’s notice	The Agency closes the VAT numbers of the businesses it represents (Agency provision of 17 April 2025, points 4.1 to 4.4).
Have a representative that files your start or change declaration asking for VIES and fails its duty to check your papers	The fine of EUR 3,000 to 50,000 falls on the representative, not on you (D.Lgs. 471/1997 art. 11(7-quinquies)). The Agency and the Guardia di Finanza target such representatives with joint risk analyses (decree of 4 December 2024, art. 4).

From 1 January 2027 the article numbers change

The Testo unico IVA (D.Lgs. 10/2026) applies from 1 January 2027 (Allegato art. 171). Until 31 December 2026 DPR 633/1972 is in force, and this page cites it. Each rule moves to a new number:

Rule	DPR 633/1972	Testo unico IVA from 2027
Representative or direct identification, joint liability	Art. 17(3)	Art. 64(3)
Start-of-activity declaration, VAT number on the home page	Art. 35(1)	Art. 68(1)
VIES guarantee	Art. 35(7-quater)	Art. 68(10)
Direct identification of a non-resident	Art. 35-ter	Art. 70
Marketplace as buyer and reseller	Art. 2-bis	Art. 7
Exemption of a supply to a marketplace treated as buyer and reseller	Art. 10, third paragraph	Art. 37(3)
Place of supply of goods	Art. 7-bis	Art. 15
Refund to a non-EU business	Art. 38-ter	Art. 120
Records, ten years for the consumer sales a marketplace facilitates	Art. 39	Art. 95
Union OSS, option for a non-EU business that ships from Italy	Art. 74-sexies	Art. 150
IOSS	Art. 74-sexies.1	Art. 151

Two other rules cited here end on 31 December 2026 too. Your own stock moved into Italy from another EU country, an intra-EU acquisition under DL 331/1993 art. 38(3)(b), becomes art. 8(3)(a) of the Testo unico IVA. The December advance of Law 405/1990 art. 6(2) becomes art. 111(1), which sets it at 88 percent of the payment for December of the year before, or of the current December if that is lower.

The fines and offences move as well. The Testo unico delle sanzioni tributarie amministrative e penali (D.Lgs. 173/2024) applies from 1 January 2027 (Allegato art. 102). From that date it repeals D.Lgs. 471/1997, and D.Lgs. 74/2000 except its arts. 21-bis and 21-ter (art. 101(1)(t), (z)). The amounts, rates and terms in the table above are the same in the new text:

Rule	Until 31 December 2026	Testo unico delle sanzioni from 2027
Start or change declaration not filed or unusable; incomplete OSS or IOSS request, EUR 500 to 2,000	D.Lgs. 471/1997 art. 5(6)	Art. 30(11)
Late payment, 25 percent	D.Lgs. 471/1997 art. 13(1)	Art. 38(1)
Annual VAT return not filed, 120 percent, at least EUR 250	D.Lgs. 471/1997 art. 5(1)	Art. 30(1)
Annual VAT return not filed where no tax is due, EUR 250 to 2,000	D.Lgs. 471/1997 art. 5(3)	Art. 30(4)
Return showing less tax than is due, 70 percent, at least EUR 150	D.Lgs. 471/1997 art. 5(4)	Art. 30(5)
Representative that does not check your papers, EUR 3,000 to 50,000	D.Lgs. 471/1997 art. 11(7-quinquies)	Art. 36(15)
Return omitted to evade more than EUR 50,000, two to five years	D.Lgs. 74/2000 art. 5	Art. 77(1), (3)
VAT above EUR 250,000 not paid, six months to two years	D.Lgs. 74/2000 art. 10-ter	Art. 83(1)

The facts for Italy, with their sources

Fact	Value	Source	Checked
Registration authority	Agenzia delle Entrate. With a tax representative, the start-of-activity declaration (form AA7/10 for a business that is not a natural person, AA9/12 for a sole trader or self-employed person) is filed only at the Direzione Provinciale of the Agency that covers the tax domicile of the representative, with the papers appointing it.	Agenzia delle Entrate, Registrazione Iva per soggetti non residenti tramite rappresentante fiscale: Come registrarsi (updated 24 February 2026)	6 October 2026
Registration authority	Agenzia delle Entrate, Centro operativo di Pescara (via Rio Sparto 21, 65100 Pescara). Direct identification with form ANR/3 is filed only there, by hand (also through a person appointed for it) or by registered post. The post route carries a copy of an identity document and the certificate of VAT status in the home state, and counts as filed on the day it is posted.	Agenzia delle Entrate, Identificazione Iva soggetti non residenti (ANR/3): Come si presenta	6 October 2026
Register	The Italian VAT number is the partita IVA, an 11-digit code shown on every invoice or other commercial document. With a tax representative or with direct identification, the foreign business stays a non-resident entity for VAT purposes.	Agenzia delle Entrate, VAT registration (English page, last update 22 September 2021)	6 October 2026
Small-volume threshold	None in the rules for a non-resident business in the texts read. The duty to act directly or through a representative attaches to carrying out operations in Italy that matter for VAT, not to an amount of turnover.	DPR 633/1972, art. 17(3) and art. 35-ter(1), text in force on 4 October 2026 (normattiva.it)	6 October 2026
Filing deadline and frequency	Direct identification: the ANR/3 declaration is filed before the first operation for which the system is used. A change in the data declared is notified within thirty days.	DPR 633/1972, art. 35-ter(1), (4), text in force on 4 October 2026 (normattiva.it)	6 October 2026
Filing deadline and frequency	The periodic VAT settlement is made by the 16th of each month for the previous month, and the amount is paid by the same day.	DPR 23 March 1998 n. 100, art. 1(1), (4) (normattiva.it)	6 October 2026
Filing deadline and frequency	A monthly payer pays an advance on the December settlement by 27 December (Law 405/1990 art. 6(2)). This page does not state the percentage: no primary text was read that settles the figure in force.	Law 29 December 1990 n. 405, art. 6(2) (normattiva.it)	6 October 2026
Filing deadline and frequency	The annual VAT return is filed electronically between 1 February and 30 April for the previous calendar year, also by a business that made no taxable sales.	DPR 22 July 1998 n. 322, art. 8(1) (normattiva.it)	6 October 2026
Filing deadline and frequency	The Union OSS return is filed each quarter by the end of the month after the quarter, nil returns included, and the VAT is paid by the same date.	DPR 633/1972, art. 74-quinquies(6), (9), applied to the Union OSS by art. 74-sexies(1), (4), text in force on 4 October 2026 (normattiva.it)	6 October 2026
Filing deadline and frequency	The IOSS return is filed each month by the end of the next month, also with no sales, and the VAT is paid by the same date.	DPR 633/1972, art. 74-sexies.1(10), (14), text in force on 4 October 2026 (normattiva.it)	6 October 2026
Penalty	Not filing a declaration of start or change of activity under art. 35 or art. 35-ter, or filing one with details so incomplete or inaccurate that the taxpayer, or the places where the activity is carried on or the books are kept, cannot be identified: a fine of EUR 500 to 2,000. The same fine applies to a non-Union OSS or IOSS registration request or change notice that is incomplete or inaccurate in the same way, including the e-mail address and website URL. It is cut to one fifth of the minimum if the filer corrects the declaration within thirty days of the office's invitation. From 1 January 2027 the same fine is art. 30(11) of the Testo unico delle sanzioni tributarie (D.Lgs. 173/2024), which replaces D.Lgs. 471/1997 from that date.	D.Lgs. 18 December 1997 n. 471, art. 5(6) (normattiva.it)	6 October 2026
Penalty	Not paying on time what is due: 25 percent of each amount not paid, halved for a delay of up to ninety days. For a delay of up to fifteen days the halved penalty is further reduced to one fifteenth of it for each day of delay. From 1 January 2027 the same rule is art. 38(1) of the Testo unico delle sanzioni tributarie (D.Lgs. 173/2024).	D.Lgs. 18 December 1997 n. 471, art. 13(1) (normattiva.it)	6 October 2026
Penalty	Not filing the annual VAT return: 120 percent of the tax due for the period, at least EUR 250. Where no tax is due: EUR 250 to 2,000. A return that shows less tax than is due: 70 percent of the extra tax, at least EUR 150. From 1 January 2027 these are art. 30(1), (4) and (5) of the Testo unico delle sanzioni tributarie (D.Lgs. 173/2024).	D.Lgs. 18 December 1997 n. 471, art. 5(1), (3), (4) (normattiva.it)	6 October 2026
Penalty	Not filing a VAT return, with intent to evade, where the tax evaded is above EUR 50,000: prison of two to five years. A return filed within ninety days of the deadline is not treated as omitted. From 1 January 2027 the same offence is art. 77(1), (3) of the Testo unico delle sanzioni tributarie (D.Lgs. 173/2024), which replaces D.Lgs. 74/2000 from that date.	D.Lgs. 10 March 2000 n. 74, art. 5 (normattiva.it)	6 October 2026
Penalty	Not paying the VAT shown in the annual return by 31 December of the year after the return was filed, where it is above EUR 250,000 for a tax period and the debt is not being paid off in instalments: prison of six months to two years. If the instalment plan lapses, the offence applies once the residual debt is above EUR 75,000. From 1 January 2027 the same offence is art. 83(1) of the Testo unico delle sanzioni tributarie (D.Lgs. 173/2024).	D.Lgs. 10 March 2000 n. 74, art. 10-ter (normattiva.it)	6 October 2026
Penalty	A representative that files the declaration of start or change of activity asking for VIES inclusion and does not check that the foreign business's papers are complete and match what it knows: a fine of EUR 3,000 to 50,000. From 1 January 2027 the same fine is art. 36(15) of the Testo unico delle sanzioni tributarie (D.Lgs. 173/2024).	D.Lgs. 18 December 1997 n. 471, art. 11(7-quinquies) (normattiva.it)	6 October 2026
Enforcement body	Agenzia delle Entrate, which with the Guardia di Finanza (the tax police) runs joint risk analyses to find the representatives of businesses outside the EU and the EEA that show danger indicators in how they check the papers of the foreign business.	Ministry of Economy and Finance, decree of 4 December 2024, art. 4 (Gazzetta Ufficiale, Serie Generale n. 292 of 13 December 2024)	6 October 2026
Local representative	A business with no permanent establishment in Italy meets its VAT duties either itself, if identified under art. 35-ter, or through a representative resident in Italy. The representative answers jointly with the business (in solido) for those duties. The appointment is told to the other party before the operation.	DPR 633/1972, art. 17(3), text in force on 4 October 2026 (normattiva.it)	6 October 2026
Local representative	Direct identification is open to a non-resident business operating in another EU state, or in a third country with which there are legal instruments on mutual assistance in indirect taxation like Directives 76/308/EEC and 77/799/EEC and Regulation (EEC) 218/92. A business from a country outside that group acts through a representative.	DPR 633/1972, art. 35-ter(5), text in force on 4 October 2026 (normattiva.it)	6 October 2026
Local representative	Businesses established in the United Kingdom may identify directly instead of appointing a representative, because the VAT protocol of the EU-UK agreement of 24 December 2020 is, in the Agency's reading, substantially similar to the EU instruments. A UK business that already had a representative or an Italian VAT number from before 1 January 2021 can keep using it for domestic operations.	Agenzia delle Entrate, Risoluzione n. 7/E of 1 February 2021, Accordo Brexit: applicabilita dell art. 35-ter, comma 5, DPR 633/72	6 October 2026
Local representative	Businesses established in Norway may also identify directly instead of appointing a representative. The Agency ruled that the VAT cooperation agreement signed by Norway and the EU on 1 August 2018 is fully analogous to the EU instruments and meets art. 35-ter(5).	Agenzia delle Entrate, Risoluzione n. 44/E of 28 July 2020, Applicabilita dell art. 35-ter, comma 5, DPR 633/72 a soggetti stabiliti in Norvegia	6 October 2026
Local representative	A representative must meet personal requirements, which it states in a declaration filed at the Agency: no conviction, even non-final, or plea sentence for financial crimes; no pending trial for financial crimes; no serious and repeated breach of social security or tax rules; and none of the conditions of art. 15(1) of Law 55/1990. For a legal person, its legal representatives make the declaration. A representative that acts for two or more businesses also gives a guarantee: EUR 30,000 for 2 to 9, EUR 100,000 for 10 to 50, EUR 300,000 for 51 to 100, EUR 1,000,000 for 101 to 1,000 and EUR 2,000,000 for more than 1,000, valid for at least 48 months.	Ministry of Economy and Finance, decree of 9 December 2024, arts. 1-3 (Gazzetta Ufficiale, Serie Generale n. 297 of 19 December 2024); Agency provision of 17 April 2025, prot. 186368	6 October 2026
National rule	VAT guarantee: a business outside the EU and the EEA that meets its VAT duties through a representative must give a guarantee to be included in the VIES database of businesses trading within the EU. The guarantee is a deposit of State securities, a bank guarantee or an insurance policy, in favour of the Agency's provincial directorate for the representative's tax domicile, with a ceiling of at least EUR 50,000. It runs for at least 36 months from delivery and need not be renewed after that.	Ministry of Economy and Finance, decree of 4 December 2024, arts. 1-2 (Gazzetta Ufficiale, Serie Generale n. 292 of 13 December 2024)	6 October 2026
National rule	How the VIES guarantee is given: a business already holding a VAT number gives it before it asks for VIES inclusion; one without a number gives it with the start-of-activity declaration that asks for VIES. A business already in VIES on 14 April 2025 had sixty days to give it. After that the Agency tells its representative by certified e-mail or registered letter that exclusion has started, and exclusion follows if the guarantee is still missing after sixty more days.	Agenzia delle Entrate, provvedimento of 14 April 2025, prot. 178713/2025, points 2 and 3	6 October 2026
National rule	IOSS in Italy: a business established in a third country with no establishment in the EU exercises the option for the import scheme through one representative appointed for that scheme, unless it is established in a third country with which the EU has a mutual-assistance agreement and ships from that country.	DPR 633/1972, art. 74-sexies.1(1), text in force on 4 October 2026 (normattiva.it)	6 October 2026
National rule	The representative requirements and guarantee, and the VIES guarantee, entered art. 17(3) and art. 35(7-quater) of DPR 633/1972 through art. 4(1)(a) and (b) of D.Lgs. 12 February 2024 n. 13, in force from 22 February 2024.	D.Lgs. 12 February 2024 n. 13, art. 4 (normattiva.it; Gazzetta Ufficiale n. 43 of 21 February 2024)	6 October 2026

Sources

Official source, opened 6 October 2026Agenzia delle Entrate, Registrazione Iva per soggetti non residenti tramite rappresentante fiscale (updated 24 February 2026)
Official source, opened 6 October 2026Agenzia delle Entrate, Registrazione Iva per soggetti non residenti tramite rappresentante fiscale: Normativa e prassi (lists the decrees and provisions below)
Official source, opened 6 October 2026Agenzia delle Entrate, Servizio di verifica dei rappresentanti fiscali (lists representatives that declared the requirements and gave the guarantee where due)
Official source, opened 6 October 2026Agenzia delle Entrate, provvedimento of 17 April 2025, prot. 186368: declaration of the personal requirements and guarantee of a tax representative
Official source, opened 6 October 2026Agenzia delle Entrate, form AA7/10: start, change or end of activity for a business that is not a natural person
Official source, opened 6 October 2026Agenzia delle Entrate, form AA9/12: start, change or end of activity for a natural person
Official source, opened 6 October 2026DPR 633/1972, art. 2-bis, supplies facilitated by electronic interfaces (normattiva.it)
Official source, opened 6 October 2026DPR 633/1972, art. 7-bis, territoriality of supplies of goods (normattiva.it)
Official source, opened 6 October 2026DPR 633/1972, art. 17, debtor of the tax (normattiva.it)
Official source, opened 6 October 2026DPR 633/1972, art. 35, declarations of start, change and end of activity, and art. 35(7-quater) (normattiva.it)
Official source, opened 6 October 2026DPR 633/1972, art. 35-ter, VAT identification of a non-resident (normattiva.it)
Official source, opened 6 October 2026DPR 633/1972, art. 38-ter, refunds to non-residents established outside the EU (normattiva.it)
Official source, opened 6 October 2026DPR 633/1972, art. 39, records, including ten years for the consumer sales a marketplace facilitates (normattiva.it)
Official source, opened 6 October 2026DPR 633/1972, art. 74-quinquies, special scheme for services by non-EU businesses, and its quarterly return (normattiva.it)
Official source, opened 6 October 2026DPR 633/1972, art. 74-sexies, Union OSS, option for a non-EU business that ships from Italy (normattiva.it)
Official source, opened 6 October 2026DPR 633/1972, art. 74-sexies.1, import scheme (IOSS) (normattiva.it)
Official source, opened 6 October 2026DL 30 August 1993 n. 331, art. 38, intra-EU acquisitions (normattiva.it)
Official source, opened 6 October 2026DPR 633/1972, art. 10, third paragraph, exemption of a supply to a marketplace treated as buyer and reseller (normattiva.it)
Official source, opened 6 October 2026DPR 633/1972, art. 19(3)(d-bis), deduction kept for that supply (normattiva.it)
Official source, opened 6 October 2026DPR 633/1972, art. 21(6)(c), the note on an invoice for an exempt operation (normattiva.it)
Official source, opened 6 October 2026DPR 633/1972, art. 36-bis, the invoicing and recording waiver and what it leaves out (normattiva.it)
Official source, opened 6 October 2026DPR 10 November 1997 n. 441, art. 1(4), forms of the appointment of a representative (normattiva.it)
Official source, opened 6 October 2026Law 29 December 1990 n. 405, art. 6(2), the December advance (normattiva.it)
Official source, opened 6 October 2026Agenzia delle Entrate, Risoluzione n. 44/E of 28 July 2020, direct identification for businesses established in Norway
Official source, opened 6 October 2026Agenzia delle Entrate, Registrazione Iva per soggetti non residenti tramite rappresentante fiscale: Come registrarsi (updated 24 February 2026)
Official source, opened 6 October 2026Agenzia delle Entrate, Identificazione Iva soggetti non residenti (ANR/3): Come si presenta
Official source, opened 6 October 2026Ministry of Economy and Finance, decree of 9 December 2024, criteria for taking the role of tax representative (Gazzetta Ufficiale, Serie Generale n. 297 of 19 December 2024)
Official source, opened 6 October 2026Ministry of Economy and Finance, decree of 4 December 2024, criteria and ways of giving the VIES guarantee (Gazzetta Ufficiale, Serie Generale n. 292 of 13 December 2024)
Official source, opened 6 October 2026D.Lgs. 10/2026 (Testo unico IVA), Allegato art. 171: the Testo unico applies from 1 January 2027 (normattiva.it)
Official source, opened 6 October 2026D.Lgs. 10/2026 (Testo unico IVA), Allegato art. 37(3), the exemption that replaces DPR 633/1972 art. 10, third paragraph (normattiva.it)
Official source, opened 6 October 2026D.Lgs. 10/2026 (Testo unico IVA), Allegato art. 64, debtor of the tax; its source note names DPR 633/1972 art. 17 (normattiva.it)
Official source, opened 6 October 2026D.Lgs. 10/2026 (Testo unico IVA), Allegato art. 68, declarations of start of activity, including the VIES guarantee in paragraph 10 (normattiva.it)
Official source, opened 6 October 2026D.Lgs. 10/2026 (Testo unico IVA), Allegato art. 70, VAT identification of a non-resident (normattiva.it)
Official source, opened 6 October 2026D.Lgs. 10/2026 (Testo unico IVA), Allegato art. 8(3)(a), intra-EU acquisitions; its source note names DL 331/1993 art. 38 (normattiva.it)
Official source, opened 6 October 2026D.Lgs. 10/2026 (Testo unico IVA), Allegato art. 111(1), the December advance; its source note names Law 405/1990 art. 6 (normattiva.it)
Official source, opened 6 October 2026D.Lgs. 173/2024 (Testo unico delle sanzioni tributarie amministrative e penali), Allegato art. 102: the Testo unico applies from 1 January 2027 (normattiva.it)
Official source, opened 6 October 2026D.Lgs. 173/2024 (Testo unico delle sanzioni tributarie), Allegato art. 101(1)(t), (z): repeal of D.Lgs. 471/1997 and of D.Lgs. 74/2000 except arts. 21-bis and 21-ter from that date (normattiva.it)
Official source, opened 6 October 2026D.Lgs. 173/2024 (Testo unico delle sanzioni tributarie), Allegato art. 30, VAT return and start-of-activity declaration fines; its source note names D.Lgs. 471/1997 art. 5 (normattiva.it)
Official source, opened 6 October 2026D.Lgs. 173/2024 (Testo unico delle sanzioni tributarie), Allegato art. 36(15), the tax representative fine; its source note names D.Lgs. 471/1997 art. 11 (normattiva.it)
Official source, opened 6 October 2026D.Lgs. 173/2024 (Testo unico delle sanzioni tributarie), Allegato art. 38(1), late payment; its source note names D.Lgs. 471/1997 art. 13 (normattiva.it)
Official source, opened 6 October 2026D.Lgs. 173/2024 (Testo unico delle sanzioni tributarie), Allegato art. 77, omitted return; its source note names D.Lgs. 74/2000 art. 5 (normattiva.it)
Official source, opened 6 October 2026D.Lgs. 173/2024 (Testo unico delle sanzioni tributarie), Allegato art. 83, unpaid VAT; its source note names D.Lgs. 74/2000 art. 10-ter (normattiva.it)
Official source, opened 6 October 2026Agenzia delle Entrate, VAT registration (English page, last update 22 September 2021)
Official source, opened 6 October 2026DPR 23 March 1998 n. 100, art. 1(1), (4) (normattiva.it)
Official source, opened 6 October 2026DPR 22 July 1998 n. 322, art. 8(1) (normattiva.it)
Official source, opened 6 October 2026D.Lgs. 18 December 1997 n. 471, art. 5(6) (normattiva.it)
Official source, opened 6 October 2026D.Lgs. 18 December 1997 n. 471, art. 13(1) (normattiva.it)
Official source, opened 6 October 2026D.Lgs. 10 March 2000 n. 74, art. 5 (normattiva.it)
Official source, opened 6 October 2026D.Lgs. 10 March 2000 n. 74, art. 10-ter (normattiva.it)
Official source, opened 6 October 2026D.Lgs. 18 December 1997 n. 471, art. 11(7-quinquies) (normattiva.it)
Official source, opened 6 October 2026Agenzia delle Entrate, Risoluzione n. 7/E of 1 February 2021, Accordo Brexit: applicabilita dell art. 35-ter, comma 5, DPR 633/72
Official source, opened 6 October 2026Agenzia delle Entrate, provvedimento of 14 April 2025, prot. 178713/2025, points 2 and 3
Official source, opened 6 October 2026D.Lgs. 12 February 2024 n. 13, art. 4 (normattiva.it; Gazzetta Ufficiale n. 43 of 21 February 2024)