For foreign companies selling into Italy
Italian VAT Registration for a UK or Foreign Company
We settle with you whether a number is needed and which route is open, then prepare the file for those who sign and lodge it.
- Direct identification or a VAT representative (Art. 17(3) D.P.R. 633/1972)
- ANR/3 is lodged only at the Centro operativo di Pescara
- The UK is a third country since 1 January 2021
- Rules as in force to 31 December 2026
Four questions come before any Italian VAT form is drafted.
Four questions before the form
Answered with you, article by article, before anything is filed. The number starts the compliance that an accounting firm in Italy carries afterwards.
Selling only to Italian VAT-registered businesses
The Italian customer accounts for the VAT under the reverse charge (inversione contabile, Art. 17(2) D.P.R. 633/1972, text to 31 December 2026). Registration is due once sales also reach consumers or buyers without a VAT number (Agenzia delle Entrate, the Italian tax authority).
A fixed place in Italy doing more than preparatory work
That is a permanent establishment (stabile organizzazione): it declares itself within 30 days and, for supplies made or received through it, leaves both non-resident routes (Art. 17(4), Art. 35(1)). A branch is one (Art. 162 TUIR, 2026 text). See opening a branch in Italy, or the detailed ready-made companies page.
Goods or services sold to EU consumers
The One Stop Shop (OSS) for distance sales and services, or IOSS for low-value imports, enters the plan; the schemes table below sets out each.
Which route is open
Direct identification (identificazione diretta) for an EU business or a third-country business with mutual-assistance instruments in indirect taxation (Art. 35-ter(5)); otherwise a resident VAT representative (Art. 17(3)). For a UK company the first is not confirmed.
Does the company need an Italian VAT number, and by which route?
1. Only Italian VAT-registered customers?
Art. 17(2) D.P.R. 633/1972
- YesReverse charge (inversione contabile): the customer accounts for the VAT; no number for those supplies
- NoSales also reach consumers or buyers without a VAT number: registration is due (Agenzia delle Entrate)
2. A fixed place in Italy doing more than preparatory or auxiliary work?
Art. 17(4), Art. 35(1); Art. 162 TUIR
- YesA permanent establishment (stabile organizzazione), declared within 30 days; for supplies made or received through it, both non-resident routes are left. A branch is one
- NoNo permanent establishment: the two non-resident routes of Art. 17(3) apply
3. Goods or services sold to EU consumers?
OSS and IOSS
- YesThe One Stop Shop (OSS) for distance sales and services, or IOSS for low-value imports, enters the plan
4. Which route is open?
Direct identification
identificazione diretta, Art. 35-ter D.P.R. 633/1972
- WhoA business established in another EU state, or in a third country with legal instruments of mutual assistance in indirect taxation (Art. 35-ter(5))
- FormANR/3, lodged only at the Centro operativo di Pescara
- UK companynot confirmedWhether the EU-UK agreements meet the Art. 35-ter(5) test is open
VAT representative
rappresentante fiscale, Art. 17(3) D.P.R. 633/1972
- WhoEvery non-resident without a permanent establishment in Italy
- FormAA7/10 for a company; for a business outside the EU and the EEA, lodged only at the Direzione Provinciale (provincial office) of the representative's tax domicile
- LiabilityThe representative answers jointly and severally with the company
Text in force to 31 December 2026; Art. 35-ter repealed from 1 January 2027
No branch is marked as recommended.
What's included
We prepare and coordinate. Your legal representative signs; a delegate or the VAT representative lodges.
- The four questions answered with their articles, the route chosen with you
- Form ANR/3 prepared for your signatory, with the enclosures Pescara asks for
- ANR/3 lodged in Pescara by a delegate or by registered post
- Representative route: the requirements of Art. 8(1)(a) to (d) D.M. 164/1999 checked
- Appointment papers drafted; the AA7/10 file assembled for the representative
- The VIES option planned; a non-EU/EEA company's guarantee file coordinated
- OSS and IOSS checked where you sell to EU consumers
- After the number: 30-day change notices and the annual VAT return calendar
Direct identification or a VAT representative
Art. 17(3) gives a company with no permanent establishment in Italy two routes. The table states the conditions; the route is chosen with you.
| Point | Direct identification (ANR/3) | VAT representative (rappresentante fiscale, AA7/10) |
|---|---|---|
| Legal basis | Art. 35-ter D.P.R. 633/1972, text to 31 December 2026 | Art. 17(3) D.P.R. 633/1972, text to 31 December 2026 |
| Who may use it | A business established in another EU state, or in a third country with legal instruments of mutual assistance in indirect taxation (Art. 35-ter(5)) | Every non-resident without a permanent establishment in Italy |
| Form | ANR/3 | AA7/10 for a company; AA9/12 for sole traders and the self-employed |
| Where it is lodged | Only the Centro operativo di Pescara, via Rio Sparto n. 21, 65100 Pescara | For a business established outside the EU and the EEA, only the Direzione Provinciale (provincial office) of the representative's tax domicile; an EU or EEA business uses the residents' filing channels |
| Who signs and who lodges | The declaration names at least one person with representation; lodged by hand through a delegate, or by registered post, counted as filed on the day of dispatch | The representative lodges, with the appointment by public deed, registered private deed or a letter entered in the office's register |
| When | Before the first transaction for which the system is adopted (Art. 35-ter(1)) | Within 30 days of starting activity (Art. 35(1)); the appointment notified to each Italian counterparty before the transaction |
| What goes with the file | By post: a copy of the declarant's identity document and the home-state certificate of VAT taxable status | The appointment deed or letter |
| Liability | The company acts directly and undertakes to produce its accounting records within the terms the requesting administration sets | The representative answers jointly and severally with the company |
| Guarantee and VIES | VIES inclusion immediate on the option (Art. 35(7-bis)) | Where the MEF criteria require it, the representative acts only after a guarantee, graded also by the number of persons represented (Provvedimento of 17 April 2025, prot. 186368); a non-EU/EEA company enters VIES only after the Art. 35(7-quater) guarantee (Provvedimento of 14 April 2025, prot. 178713), and the representative checks its file |
| From 1 January 2027 | Art. 35-ter repealed by D.Lgs. 10/2026 | The consolidated VAT text of D.Lgs. 10/2026 applies |
Sources: Art. 17 D.P.R. 633/1972; Art. 35-ter D.P.R. 633/1972; Art. 35 D.P.R. 633/1972; the Agenzia's ANR/3 and representative pages, October 2026.
The UK position, settled and open
What the statute and the Agenzia say about a UK company, and what stays open.
| Point | What the source says | Status | Source |
|---|---|---|---|
| The UK's status | A third country for Italian VAT from 1 January 2021 | Settled | Agenzia Brexit FAQ |
| The test for direct identification | A third country needs legal instruments of mutual assistance in indirect taxation; the Agenzia checks for cooperation agreements like the EU's | Settled | Art. 35-ter(5); Agenzia Brexit FAQ |
| Whether the EU-UK agreements meet the test | The Agenzia said it would clarify once its analysis was complete | Open: no later clarification in the sources we read | Agenzia Brexit FAQ |
| UK operators already identified directly | The FAQ suggested they consider closing that number on ANR/3 and asking for a new one on AA7/10 or AA9/12 through an Italian tax representative | The Agenzia's suggestion, undated; not advice of ours | Agenzia Brexit FAQ |
| Activity ceasing in the home state | Cessation declared within 30 days | Settled | Agenzia Brexit FAQ |
| The representative route | Open to every non-resident without a permanent establishment | Settled | Art. 17(3) |
| From 1 January 2027 | Art. 35-ter repealed by D.Lgs. 10/2026; the consolidated VAT text applies; its successor provision is not printed here | Settled | Art. 35-ter, version from 1 January 2027 |
Sources: Agenzia delle Entrate, Brexit FAQ (an undated section kept in the portal's archive); Art. 35-ter in the version from 1 January 2027.
How the registration runs, route by route
Each duration is labelled law, Agenzia or planning estimate; an estimate is never a promise.
law a term set by statuteestimate a planning estimate, never a promiseno term no statutory term found
Route A: direct identification
ANR/3, Centro operativo di Pescara
- 2. Gather the declarationestimate Name and seat abroad, a person with representation, the home tax office and VAT number, the undertaking on the books (Art. 35-ter(2)); paced by the home tax authority's certificate
- 3. Lodge ANR/3 in Pescaralaw Before the first transaction for which direct identification is used, by a delegate or by registered post, counted as filed on the day of dispatch (Art. 35-ter(1))
- 4. The number is assignedno term A partita IVA (Italian VAT number) showing non-resident status; VIES inclusion immediate on the option (Art. 35(7-bis))
Route B: VAT representative
AA7/10, the representative's Direzione Provinciale
- 5. Choose and check the representativeestimate The requirements of Art. 8(1)(a) to (d) D.M. 164/1999 and, where due, a posted guarantee
- 6. Appoint the representativeestimate By public deed, registered private deed or a letter entered in the office's register; a deed drawn up by a foreign authority is legalised and translated unless exempt (Art. 33 D.P.R. 445/2000)
- 7. The representative lodges AA7/10law Within 30 days of starting activity (Art. 35(1))
- 8. VIES guarantee and notice to customerslaw A non-EU/EEA company lodges the Art. 35(7-quater) guarantee before VIES; each Italian counterparty is told of the appointment before the transaction (Art. 17(3))
No day count for the number
Settle the four questions
We answer the four questions with you, each with its article, and choose the route.
Planning estimate: one working session; no statutory term
Route A: gather the declaration
Name and seat abroad, a person with representation, the home tax office and VAT number, and the undertaking on the books (Art. 35-ter(2)). We prepare the form.
Planning estimate: depends on the home tax authority's certificate; no statutory term
Route A: lodge ANR/3 in Pescara
Before the first transaction for which direct identification is used, by a delegate or by registered post, counted as filed on the day of dispatch (the Agenzia's ANR/3 page).
Law: Art. 35-ter(1)
Route A: the number is assigned
A partita IVA (Italian VAT number) showing non-resident status (Art. 35-ter(3)); VIES inclusion is immediate if the option was expressed (Art. 35(7-bis)).
No statutory term found for the number
Route B: choose and check the representative
The requirements of Art. 8(1)(a) to (d) D.M. 164/1999 and, where due, a posted guarantee; the Agenzia lists registered representatives (the Agenzia's representative page).
Planning estimate: no statutory term
Route B: appoint the representative
By public deed, registered private deed or a letter entered in the office's register. A deed drawn up by a foreign authority, such as a UK notary, needs its signatures legalised by the Italian consulate and, if not in Italian, a certified Italian translation, unless a law or an international agreement exempts it (Art. 33 D.P.R. 445/2000).
Planning estimate: no statutory term; legalisation and translation set the pace
Route B: the representative lodges AA7/10
At the Direzione Provinciale of its tax domicile, with the appointment papers; we plan it before the first transaction.
Law: within 30 days of starting activity (Art. 35(1))
Route B: VIES guarantee and notice to customers
A non-EU/EEA company lodges the Art. 35(7-quater) guarantee before VIES, and the representative checks its file; each Italian counterparty is told of the appointment before the transaction.
After the number: data changes within 30 days (Art. 35-ter(4)), the annual VAT return between 1 February and 30 April (Agenzia delle Entrate), OSS returns where chosen, and a check of the new texts before any filing dated 2027 or later. Other taxes, such as tax on the sale of Italian shares or how S.r.l. quotas pass on death in Italy, follow their own rules.
Law: Art. 17(3), Art. 35(7-quater)
Not sure which route is open to your company?
We settle the four questions with you, and the UK test where it applies, before any form is drafted.
Documents a UK company provides
What the company produces, by route; we check each item before filing.
- The certificate of VAT taxable status held in the home state (postal ANR/3)
- The UK VAT number, or the UK tax identification code failing one
- A copy of the signing director's identity document
- Company name, registered seat abroad and the activity carried on there
- The data of at least one person with representation
- Route B: the appointment deed or letter; a deed drawn up by a foreign authority legalised and translated unless exempt
- VIES through a representative: the guarantee under the Provvedimento of 14 April 2025
Selling to EU consumers from the UK, OSS and IOSS
Consumer sales add a scheme to the plan. The table shows who may use each one in Italy; joining the scheme is planned with you.
| Scheme | Who and what | Italy's role | Basis |
|---|---|---|---|
| OSS, Union scheme | A seller domiciled or resident outside the EU, with no EU establishment, dispatching goods from Italy | The Italian VAT number already assigned is used; where goods also leave other member states, the option cannot be revoked before the end of the second year after it is made | Art. 74-sexies(2) and (3) D.P.R. 633/1972, text to 31 December 2026 |
| OSS, non-Union scheme | A business established outside the EU supplying services to EU consumers, from 1 July 2021 | Italy may be chosen as the state of identification | Agenzia Brexit FAQ, answer on a company established in Great Britain |
| IOSS | Distance sales of goods imported from third countries with a value of no more than EUR 150 | Declared in one place through the Import One Stop Shop | European Commission, VAT identification numbers page |
| The EUR 10,000 distance-selling threshold | A supplier established in a single member state | Our reading of the condition: a business established outside the EU does not meet it, so a UK seller has no such threshold | Art. 41(1)(b) D.L. 331/1993 |
Sources: Art. 74-sexies D.P.R. 633/1972; Agenzia Brexit FAQ; European Commission; Art. 41 D.L. 331/1993.
Problems we solve
Five points in a foreign company's Italian VAT file, and how we handle each.
VIES that was never switched on
Inclusion is immediate on the option (Art. 35(7-bis)); through a representative, a non-EU/EEA company first lodges a guarantee (Art. 35(7-quater)). We put both in the plan.
No date for the number
We found no statutory term for assigning the number on either route. We plan the filing before the first Italian transaction (Art. 35-ter(1)) and promise no day.
UK papers Italy will not take as they are
Documents drawn up by foreign authorities need consular legalisation and, if in a foreign language, a certified Italian translation, unless a law or an international agreement exempts them (Art. 33 D.P.R. 445/2000). We check what each UK document needs before it is signed.
A number taken under Art. 35-ter before 2021
The Agenzia's Brexit FAQ suggested considering a cessation on ANR/3 and a new number through a representative. We set out the options; the company decides.
The books and the yearly filings
The direct-route declarant undertakes to produce its accounting records (Art. 35-ter(2)(e)). The annual VAT return goes through an Art. 3(3) D.P.R. 322/1998 intermediary or the company; the calendar is in our guide, tax return Italy.
Is your UK company already identified in Italy?
We set out the Agenzia's suggestion and your options with you; the company decides what to close or open.
Why work with us
Andrea Sala
Tax and Cross-Border Compliance Lead, Milan: VAT for companies established abroad and the tax representative.
From our practice
we answer the four questions with their articles before drafting a form, and each step of the plan names who signs, who lodges and who answers for the VAT. We prepare and coordinate; returns go through an authorised intermediary or the company.
Frequently asked questions
Can a UK company register directly with ANR/3, without a representative?
Only if the UK is a third country with legal instruments of mutual assistance in indirect taxation (Art. 35-ter(5) D.P.R. 633/1972, 2026 text). The Agenzia's Brexit FAQ treats the UK as a third country from 1 January 2021 and left this to a later clarification, which we did not find. We neither promise nor rule out the direct route.
Our UK company already holds an Italian number under Art. 35-ter. What now?
The Agenzia's Brexit FAQ suggested that UK operators identified directly consider closing that number on ANR/3 and asking for a new one on AA7/10 or AA9/12 through an Italian tax representative. Where activity ceases in the home state, the cessation is declared within 30 days. We set out the options with you; the choice is the company's.
What does a VAT representative take on?
Joint and several liability with the company for its Italian VAT (Art. 17(3) D.P.R. 633/1972, text to 31 December 2026). The representative must meet the requirements of Art. 8(1)(a) to (d) D.M. 164/1999 and, where the MEF criteria require it, acts only after posting a guarantee. The appointment is notified to each Italian counterparty before the transaction.
Will FormaItalia act as our VAT representative?
We prepare the appointment papers and the AA7/10 file, and coordinate a representative who declares the statutory requirements of Art. 8(1)(a) to (d) D.M. 164/1999 and, where due, has posted the guarantee. The representative lodges the file, for a non-EU/EEA company at its Direzione Provinciale, and answers jointly and severally with the company for its Italian VAT.
How long does the registration take?
No statutory term for assigning the number was found on either route. The law fixes when to file: ANR/3 before the first transaction for which direct identification is used (Art. 35-ter(1) D.P.R. 633/1972, text to 31 December 2026), a start-of-activity declaration within 30 days (Art. 35(1), same text). We plan around those terms and promise no date.
How much does the registration cost?
Our fees are quoted on request once the route is known: direct identification or a representative, the VIES option, OSS or IOSS, and the documents to be translated and legalised. Where a guarantee is due, the company lodges it under the MEF criteria and the Agenzia's Provvedimento of 14 April 2025. Pricing on request.
Can a UK company trade with EU businesses through VIES?
Inclusion in VIES is an option in the declaration and takes effect immediately (Art. 35(7-bis) D.P.R. 633/1972, text to 31 December 2026). Through a representative, a business outside the EU and EEA first lodges the Art. 35(7-quater) guarantee and the representative checks its file. Four consecutive quarters without a recapitulative statement lead to presumed exclusion, after notice.
Does a UK company need an Italian VAT number at all?
Not while it sells only to taxable persons established in Italy: the Italian customer accounts for the VAT (Art. 17(2) D.P.R. 633/1972, text to 31 December 2026). The Agenzia says the duty arises when sales also reach consumers or buyers without a VAT number; a fixed place in Italy doing more than preparatory work is a permanent establishment.
Where and how is each route filed, and what does the company send?
ANR/3 goes only to the Centro operativo di Pescara, by hand through a delegate or by registered post, before the first transaction, with the declarant's identity document and the home-state VAT status certificate (Agenzia delle Entrate). On the representative route, a non-EU/EEA business files AA7/10 at the Direzione Provinciale of the representative's tax domicile, with the appointment papers.
Is there a registration threshold?
The sources read set no turnover threshold for a non-resident company: registration follows sales to consumers or buyers without a VAT number, or a permanent establishment. Art. 41(1)(b) D.L. 331/1993 (text to 31 December 2026) sets a EUR 10,000 distance-selling threshold for a supplier established in one member state, closed to a UK seller on our reading.
Can a UK company use OSS in Italy?
For services to EU consumers, the non-Union OSS with Italy as the state of identification (Agenzia Brexit FAQ). For intra-EU distance sales of goods dispatched from Italy by a non-EU seller with no EU establishment, the Union OSS in Italy (Art. 74-sexies D.P.R. 633/1972, 2026 text). Imports of up to EUR 150 go through IOSS (European Commission).
When is a VAT number the wrong tool and a branch the right one?
When the company has a fixed place of business in Italy that does more than preparatory or auxiliary work (Art. 162 TUIR, 2026 text). That is a permanent establishment, which declares itself within 30 days (Art. 35(1) D.P.R. 633/1972) and, for supplies made or received through it, leaves the two non-resident routes (Art. 17(4)).
Does Italy issue a VAT registration certificate, and is there a template?
The office issues or sends a certificate of attribution of the VAT number (Art. 35(7) D.P.R. 633/1972, text to 31 December 2026). With a postal ANR/3, the company itself sends the certificate of VAT taxable status held in its home state (Agenzia delle Entrate). We offer no template: none is held in the sources we read.
What changes after registration, and is the law about to change?
Data changes are declared within 30 days (Art. 35-ter(4)); the annual VAT return runs 1 February to 30 April. A start or change declaration omitted, or too incomplete or inaccurate to identify the company or its places of business, costs EUR 500 to EUR 2,000 (Art. 5(6) D.Lgs. 471/1997, 2026 text). Art. 35-ter is repealed from 1 January 2027.
Ready to plan the Italian VAT registration?
Tell us where the company is established and what it sells into Italy; we reply with the route and the file.