Italy extends the deadline for exercising the right to recover input VAT

Under the previous framework, introduced by Law Decree No. 50/2017, input VAT had to be recovered by the filing deadline for the annual VAT return relating to the year in which the right arose (30 April of the following year). The amended Article 19 of the Italian VAT Decree extends this to the filing of the return for the following year, while Article 25 is adjusted accordingly for invoice registration. For instance, a business purchasing goods on 21 July 2026 and receiving the related invoice on 27 October 2026 will now have until the 2028 annual VAT return (to be filed by 30 April 2029) to recover the input VAT. Under the former provision, the same taxpayer would have had to claim recovery by 30 April 2027. As illustrated in the Explanatory Report accompanying the decree, the 2017 restriction was originally intended to bring recovery closer to invoice registration, thereby facilitating tax controls. However, mandatory e-invoicing - fully operational since 2019 – has removed the risks that had justified the shorter deadline, as recovery can no longer be exercised without prior receipt of the mandatory e-invoice. Importantly, the decree contains no transitional provisions, leaving open the question of whether the extended deadline may also apply to input VAT relating to prior fiscal years (2024 and 2025).

Key takeaway / recommendation

Businesses operating in Italy should review their internal VAT compliance workflows and VAT recovery tracking processes in light of the extended deadline. In particular, companies should evaluate whether any input VAT from the 2024 or 2025 fiscal years – previously considered time-barred – could now be recovered under the amended rules. However, as the decree is silent on transitional arrangements, monitoring official guidance will be essential to seize potential recovery opportunities and avoid compliance risk.

Reference

Legislative Decree No. 148 of 7 August 2026 (so-called "Omnibus Corrective Decree"), Article 12: DECRETO LEGISLATIVO 7 agosto 2026, n. 148 - Normattiva.