he ruling issued by the Italian Tax Authority (Agenzia delle Entrate) on July 24, 2025, No. 193, analyzes the conditions under which the permanent establishment of a non-resident company in Italy plays a significant role in purchases carried out in Italy.
According to the Authority, it is not sufficient for the Italian permanent establishment to conduct economic assessments of the purchases; what is decisive is the negotiation and conclusion of the commercial agreements.
In the absence of material involvement by the Italian permanent establishment, the purchases are considered to be carried out directly by the non-resident parent company. From a compliance standpoint, the operations carried out in Italy by the parent company must be kept separate from those related to the Italian VAT position of the permanent establishment (via separate entries in the VAT ledgers and submission of a specific section in the annual VAT return)
