The chargeability of VAT in split payment: a two-faced Janus? / Corriere Tributario 3/2025

In “Corriere Tributario” no. 3 of 2024, Pierpaolo Maspes and Raffaele Corso analyze the Revenue Agency’s response to ruling no. 210/2024, which addresses the relationship between the split payment discipline and the right to reduce the taxable base. The response to ruling no. 210/2024, according to the authors, raises some doubts of a systematic nature in the particular case in which the customer makes use of the optional provisions that allow anticipate the remittance of VAT from the split payment mechanism by referring to the moments, prior to that of payment of the consideration, of receipt of the invoice or registration of the same on the VAT ledger. Since the time of chargeability of VAT must be known by both parties to the transaction and must coincide, they believe that the annual term for reducing the taxable base by supervening agreement between the parties can only start from the date on which the payment of the transaction takes place even if the customer applies the aforementioned derogatory criteria for the remittance of VAT from split payment.

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