With Circular No. 5/E of 16 May 2025, the Italian Revenue Agency provided important clarifications on the new VAT classification of personnel secondments, following the repeal - with the Salva Infrazioni decree - of the rule that excluded from VAT reimbursements related only to the cost of the worker.

Confindustria had already highlighted the critical application issues that emerged following the reform, with particular reference to secondments by non-commercial entities. The Circular accepted the observations previously provided, confirming that transactions carried out by non-commercial entities as part of their institutional activity are not subject to VAT.

It is also confirmed that the new rules only apply to contracts concluded or renewed from 1 January 2025and that all previous conduct will not be sanctioned.

Confindustria welcomes the Agency's approach, which protects the specificities of the association system and offers certainty to operators in a phase of regulatory transition.

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