The Confindustria document dwells on some of the critical profiles of the measure: in particular, the proposed changes to the cases of violations of VAT-relevant transactions and the rewriting of the rules on penalties for undue offsetting of non-existent and not due tax credits.

With regard to VAT, we share some reflections related to the changes on violations for undue VAT deduction on the regularisation procedure for omitted or irregular invoicing and on certain foreign transactions.

These are positive interventions, but there are a number of critical issues.

With reference, on the other hand, to penalties for undue offsetting of tax credits, the intervention aimed at remodelling the burden of penalties and at making a stricter distinction between non-existent tax credits and tax credits that are not due, in accordance with one of the delegation criteria, appears to be agreeable; however, further clarifications and simplifications are necessary to ensure a clear and consistent application of the legislation.