Italy’s Official Gazette number 138 has published Decree Law 84 of 17 June 2025, which includes several new fiscal measures, among them the extension of the reverse charge mechanism to road haulage services. However, the measure will only take effect once it has received the green light from the European Commission. Only after Brussels’ approval, to be published in the Official Journal, and the adoption of an implementing ministerial decree, will the new regime be operational. A three-year transitional phase is planned. In the meantime, companies are expected to prepare accordingly.
Until now, this mechanism had only applied in limited cases, subject to particularly strict criteria: the service had to involve predominantly the use of labour and equipment provided by the client. This definition effectively excluded the vast majority of standard third-party transport operations. The new decree removes this limitation, paving the way for all road haulage and logistics services to be invoiced without VAT, which will instead be accounted for directly by the client through a self-invoice.
From an operational standpoint, the change entails a number of significant adjustments. First and foremost, management software must be updated to issue electronic invoices without VAT, using the appropriate code required for reverse charge. The new system will also require a review of VAT ledgers and settlement procedures, with particular attention to the correct reporting of data in periodic declarations. Companies managing both domestic and international transport, or transactions involving non-resident clients, will need to ensure their systems are flexible enough to accommodate different VAT regimes.
One immediate benefit will be improved liquidity. No longer having to advance VAT on issued invoices – often with payments delayed by several months – means freeing up financial resources, with a positive impact on working capital. However, this financial advantage comes with an operational risk: companies will continue to bear input VAT costs (fuel, maintenance, leasing, purchases), while collecting payments without VAT. This may result in structural VAT credits, which will need to be managed carefully through tools such as VAT ceilings, refund requests or offsets against other taxes.
Another key feature introduced by the decree is the possible extension of the reverse charge to subcontracting chains. This would allow the mechanism to apply to relations between main contractors and subcontracted hauliers. In such cases, however, the main contractor will be jointly liable for any VAT unpaid by the subcontractor, creating a compliance burden that may prompt companies to reassess their supplier selection, existing contracts and document workflows.
The new VAT framework will also have implications for commercial contracts. In many cases, price clauses will need to be revised to clearly state net amounts excluding VAT and to update general terms and conditions to reflect the new way of fulfilling tax obligations. In dealings with public authorities or public tenders, the applicable VAT regime must be clearly specified to avoid misunderstandings or disputes.
The introduction of the reverse charge mechanism in road haulage is therefore much more than a technical amendment. It is a structural shift that affects accounting processes, contractual relationships, IT systems and financial management. Businesses that act early – by monitoring legislative developments, updating procedures and training administrative staff – will manage the transition more smoothly, avoiding disruptions and making the most of the opportunities brought by the new system.
