Use of Electronic Invoice Data by the Italian Tax and Customs Authorities

Edited by Andrea Werner Beilin, Lorenzo Pirola and Luca Masotti

Since 2019, with the introduction of the general mandatory electronic invoicing requirement, the use of data relating to invoices transmitted through the Exchange Data System (i.e. SdI) is central to the Tax Authorities’ audit and control processes.

Moreover, with a view to expanding the assessment activities carried out by the authorities, additional reporting obligations and processes were introduced, including:

the submission of the data related to cross-border transactions, the so-called “Esterometro”;
the electronic transmission of daily receipts, to which the obligation to link electronic payment systems has recently been added (please refer to our previous Newsletter November 18, 2025); and
the re-engineering of the customs IT system with reference to import and export transactions involving goods.

Based on the information assets currently available, the Tax Authorities own verification tools that trigger automated controls and the issuance of so-called “compliance letters” (please refer to our previous Newsletter October 29, 2025 and Newsletter June 15, 2026) whereby taxpayers are invited to regularise their tax position on the basis of the information already held by the Tax Authorities.

This process has been progressively strengthened in recent years, confirming the shift towards an advance control model, under which taxpayers are encouraged to comply before the start of any potential tax assessment.

Against this background, particular relevance is assumed by both the recent Tax authorities’ Act No. 153611/2026, concerning tax recovery activities, and Article 25 of the draft fourth corrective fiscal decree, which expands the use of data by the Italian Customs Authorities.

Electronic invoices supporting the Tax Collection Authorities

Article 1, par. 117, of Law No. 199/2025 introduced letter b-ter) into Article 1, par. 5-bis, of Legislative Decree No. 127/2015, extending the use of electronic invoice data also to tax collection activities.

In particular, under the new provision, the Italian Tax Authorities may make available to the Italian Tax Collection Authorities (hereinafter also the “Collection Agent”) data relating to invoices and daily considerations issued by debtors registered on the tax roll (i.e., persons with tax liabilities entrusted to the Collection Agent), as well as by the related jointly liable parties.

From an operational standpoint, the new measure enables the Collection Agent to identify potentially attachable commercial relationships more promptly, based on the most recent electronic invoicing flows, thereby significantly strengthening the effectiveness of tax recovery activities.

Electronic invoices supporting the Italian Customs Authorities

Article 25 of the draft fourth corrective fiscal decree expands the purposes for which electronic invoice data may be used by the Italian Customs Authorities.

According to the draft decree, such data may also be used for risk analysis and control activities for tax and customs purposes.

More specifically, the regulatory amendment affects Article 1, par. 5-bis, of Legislative Decree No. 127/2015, providing that the information assets deriving from electronic invoice files, stored until 31 December of the eighth year following the year in which the relevant return is filed or until the conclusion of any litigation, may also be used for customs risk analysis and for controls relating to matters falling within the competence of the Italian Customs Authorities.

Tax data control and prevention of anomalies

The progressive integration of tax and customs databases, together with the use of digital information, requires the taxpayers to ensure enhanced control of the accuracy and consistency of the information transmitted to the Tax Authorities.

In this context, it is important to adopt control tools already as part of periodic compliance activities, to prevent and mitigate any reports of irregularities by the competent authorities.

PwC Tax STP S.r.l. is available to support businesses with the ongoing monitoring and implementation of controls on the data communicated to the Tax Authorities.