On 22 August 2025, the Italian Tax Authorities issued an important clarification of significant relevance to businesses engaged in cross-border transactions.
In Ruling No. 213/2025, the Authorities confirmed that an importer may recover VAT paid at Customs even if the importer is not the owner of the goods, provided there is a direct and immediate connection with its business activity (specifically between the goods’ entry into Italy and their subsequent dispatch).
The right to deduct is valid where the Customs invoice is properly recorded in the VAT purchase ledger and, more generally, in the company’s accounts.
The clarification was issued in response to a case involving an Italian company that imported active ingredients, processed them into pharmaceuticals, and resold them to the owner for export.
For third-party importers, this decision offers valuable guidance and underscores the importance of maintaining appropriate documentation and demonstrating a clear commercial link to support VAT recovery.
