In recent years, the tax management of transport operations as well as the movement of goods and logistics has received increasing attention from Italian and European authorities. One of the most significant innovations has been the proposal to introduce Reverse Charge in contracts for procurement and subcontracting for these activities. Following important regulatory updates in the last months of 2025, particularly with the entry into force of Decree Law No. 84/2025 (the "Tax Decree"), this regulation is not only close to becoming structural, but has also seen the removal of some initially foreseen constraints. Although full implementation is still underway, it represents a decisive step forward in combating tax fraud and simplifying VAT management in a crucial sector.
But how did we arrive at this proposal and what problems does it aim to solve, considering the latest changes? What could be the practical impacts for industrial companies operating in the logistics and transport sector?
A tool to combat VAT evasion in Italy
Italy is making significant progress in the fight against tax evasion, particularly regarding VAT. According to the CPI Observatory, overall evasion has decreased from €108.4 billion in 2017 to €82.4 billion in 2021, with a notable reduction in VAT evasion, which fell from €35.6 billion to €17.8 billion during the same period.
In 2023, the Revenue Agency recorded a record recovery of €24.7 billion, an increase of 22% compared to the previous year.
Despite these advances, VAT evasion remains a significant challenge. In 2022, thetax gapfor VAT in the European Union was estimated at €89.3 billion, with Italy representing a significant part of this gap.
In this context, the adoption of the Reverse Charge mechanism in the logistics and transport sector is emerging as an effective measure to further combat VAT evasion, transferring the obligation to pay the tax from the supplier to the client and thus reducing opportunities for fraud.
Why reverse charge is becoming a tax priority and is expanding
The Reverse Charge, or reverse accounting, is a mechanism that transfers the obligation to pay VAT from the supplier to the client. This system has been introduced in various sectors considered at risk of tax fraud and is now at the centre of attention for its application to logistics and transport. The proposal, initially included in the 2025 Budget Law and then strengthened and expanded by Decree Law No. 84/2025, aims to obtain the European Union's authorisation to become structurally effective.
A key point of the latest updates is the removal of the requirements for "predominant use of labour" or "use of client assets" that had initially been proposed. This means that the regulations will apply indiscriminately to all contracts for procurement, subcontracting, assignments to consortium members or similar in the logistics and transport sector, significantly expanding the range of affected operations and making the mechanism more robust in combating fraud.
This regulation has been developed in response to specific issues in the sector. In particular, it aims to combat unfair practices by consortium structures that issue invoices with VAT to the client without then proceeding to make the corresponding payment, closing the companies involved and transferring the workers to other companies in the consortium.
Often the client remains unaware of such irregularities, as the only contractual interlocutor is the lead company of the consortium, which manages all invoicing.
Let us imagine the case of company Alfa, an important industrial entity that enters into a procurement contract with company Beta for the management of logistics services. Company Beta, in turn, is a consortium that relies on consortium companies to provide the necessary labour. Alfa regularly receives invoices from Beta, including VAT, and ensures that all documentation (DURC, DURF and various certifications) is in order.
However, beneath the surface of this seemingly transparent relationship lies a fraudulent mechanism. One of Beta's consortium members, Company A, provides personnel and invoices Beta with VAT without ever paying the tax to the treasury. After a certain period, Company A is closed, and the personnel are transferred to Company B, another member of the Beta consortium. Company B continues the same practice: it issues invoices with VAT, does not make the required payments, and before the tax authorities can intervene, it is closed, transferring the personnel again to a third consortium company, Company C. This cycle repeats, generating a chain of systematic tax evasion.
Although Company Alpha is completely unaware of the irregularities within the Beta consortium, it still exposes itself to significant risks. Although formal checks appear to be regular, the tax authorities may consider that the relationship between Alpha and Beta is not a genuine contract for services, but rather an illegal provision of labour, under Article 10 of Legislative Decree 276/2003. This reclassification could arise from an operational management that does not meet the typical criteria of a contract, such as the lack of organisational autonomy on the part of Beta or direct control by Alpha over the consortium workers. In such a scenario, Alpha could lose the right to deduct VAT and be subject to tax and contribution penalties, even without having any awareness of the violations committed within the consortium.
What would change in this situation with the application of reverse charge?
In this case, the Reverse Charge would represent an effective solution to prevent tax fraud and protect company Alfa. With the reverse charge mechanism, VAT would no longer be paid to consortium Beta, but directly to the treasury by Alfa. This mechanism would prevent the consortium members (A, B, C) from retaining VAT without paying it, blocking the fraudulent cycle of closures and reopenings.
Current status and possibilities for voluntary agreements: The news
At present, the Reverse Charge in logistics and transport subcontracting contracts is awaiting final approval from the European Union for structural application. However, it is already possible for companies to enter into voluntary agreements between the provider and the client, whose transitional regulations have been aligned with the future structural regime. These agreements stipulate that VAT is paid by the client on behalf of the provider, offering a proactive solution.
Important news: with the recent amendments to Decree Law No. 84/2025, every subcontractor can now independently exercise the transitional option for voluntary agreements, even in the absence of a choice by the client or the main contractor, offering greater flexibility throughout the supply chain.
The voluntary agreements, lasting three years, require prior communication to the Revenue Agency and are particularly useful for companies that want to anticipate the benefits of future regulations and start mitigating tax risks from now on. Furthermore, starting from 1st October 2025, the payment of VAT related to these operations (when due via Reverse Charge) will occur quarterly, by the 16th of the second month following each calendar quarter.
Optimising compliance for a more transparent future
In a constantly evolving sector, choosing reliable partners and staying updated on regulations is essential. With the Reverse Charge and its recent extensions that strengthen its application, the path towards a more transparent and secure logistics is finally mapped out.
For companies looking to reduce tax risks and improve VAT management, entering into voluntary agreements can represent a useful solution while awaiting the implementation of the final regulations. It is essential to continue monitoring the evolution of the regulatory framework to adapt promptly to new provisions and seize the opportunities offered by greater tax transparency.