Law and regulation
ANAS S.p.A. and incorrectly applied VAT reverse charge for abnormal transport
• 2 min read
An audit at ANAS S.p.A. led to debit notes with Italian VAT for foreign companies in abnormal transport, with a possible loss of refund rights.
Audit of ANAS S.p.A. by the Italian tax authorities
ANAS S.p.A. has recently undergone an audit by the Italian tax authorities. ANAS (Azienda Nazionale Autonoma delle Strade) is the public body responsible for the management and maintenance of a large part of Italy's national road network.
Incorrect VAT reverse charge for abnormal transport
A recent audit has shown that foreign customers active in abnormal transport were invoiced incorrectly for years under the VAT reverse charge mechanism, while Italian VAT should in fact have been charged in these situations.
Debit notes issued to foreign companies
As a result, debit notes have been sent to the foreign companies concerned. These relate exclusively to the VAT. This is not a corrected invoice with a new invoice date, but a separate calculation of the VAT on earlier invoices. This VAT is imposed as a new debit note and in many cases relates retroactively to earlier periods, including 2024.
Impact for foreign transport operators
For foreign companies active in abnormal transport in Italy, this situation can have significant consequences.
When debit notes are issued with an invoice date in a financial year that has already been closed, this can lead to a complex tax position. The deadline for reclaiming foreign VAT follows fixed European deadlines. For invoices from 2024, for example, the final submission date was 30 September 2025.
If a company only receives the debit note after that deadline has passed, this may mean that the right to recover the VAT can no longer be exercised. This creates a financial risk outside the company's control.
Support with international VAT and excise issues
Situations like this require specialist knowledge of international VAT rules and refund procedures.
At Delta, we monitor these developments closely and support businesses with complex issues relating to foreign VAT and excise refunds.
Timely insight into your tax position
Are you confronted with debit notes or corrections from abroad, or do you have questions about the consequences for your refund position? Then it is important to gain timely insight into your tax options and position.
International tax rules change continuously. A well-informed and specialist approach makes the difference.
