The commissions received by digital platforms for the rental of goods are not subject to the withholding tax provided for under Art. 25-bis of Presidential Decree 600/73.
The reasoning lies in the nature of the contractual relationships, which are not among those exhaustively listed in the provision (Italian Revenue Agency Ruling, 18 September 2025, No. 250). According to the Agency, the fees received by the platform for rental activities are not subject to withholding tax under Art. 25-bis DPR 600/73, which applies solely to contracts expressly specified in the law, namely commission, agency, mediation, commercial representation, and business procurement.
