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May 14, 2023 International Transportation

Clarifications from the Internal Revenue Service

By circular no. 5/E/2022 the Internal Revenue Service provided clarification regarding international transportation services performed by sub-carriers and the effective date of the new provisions.

Specifically, non-taxability is limited to territorially relevant transactions in Italy and does not extend to relationships between carriers, transport agents and sub-carriers.

The clarifications provided in Circular no. 5/E/2022

Last February 25, 2022, Revenue Agency Circular No. 5/E in this regard recalls that, since the transportation services under consideration fall within the scope of Article 7b(1)(a) of the same Presidential Decree No. 633 (general services), the aforementioned Article 9 applies to services rendered to purchasers who are taxable persons established in the territory of the state, as territorially relevant services in Italy.

It follows that, for the hauler, the VAT regime (non-taxable Article 9 – taxable VAT – not subject to VAT under Article 7-ter) should be applied in the cases shown in the following summary table:

Lender Client Transport Applicable VAT regime
IT Driver EU Operator IT


IT – Non-EU

Not subject to VAT

ex art. 7-ter

Non-EU Operator
IT Operator IT


Taxable VAT (*)
IT operator exporter, transit holder, importer, consignee of goods, shipping service provider/customs operations IT – Non-EU

Non-EU – IT

Not taxable VAT ex art. 9 – DPR 633/72
IT operator other than the above Taxable VAT


(*) Except for the non-application of VAT following the issuance of the declaration of intent by the IT operator who qualifies as a regular exporter.