Italy: New technical specifications for e-invoicing mandatory from 2021


published on 9 October 2020 | reading time approx. 3 minutes


As of 1 January 2021, the adoption of the new technical specifications (version 1.6.1) approved by Provision no. 99922/2020 of 28 February 2020 and subsequently amended by Provision no. 166579 dated 20 April 2020 for the issue of electronic invoices and variation notes will become mandatory. Therefore, from 2021 on, the Interchange System (SDI) will only accept electronic invoices and variation notes whose XML file is set up on the basis of the new XML format, which can already be used on optional basis as from 1 October 2020.



The main new features of this XML-version are the introduction of new “Type of document” codes, further details of the “Nature of transaction” codes and new “Type of Withholding" and “Type of Payment” codes.



New Type of document codes

As regards the “Type of document” codes, there are 11 new identifiers (which therefore rise from 7 to 18) in order to simplify the identification of certain accounting operations.
In particular, specific codes have been provided for reverse charge operations:

  • TD16 - Application of the reverse charge procedure through invoice integration on internal acquisitions;
  • TD17 – Invoice integration or self-billing for the purchase of services from non-resident subjects (ex art.17 c.2 DPR 633/72);
  • TD18 - Application of the reverse charge procedure to intra UE acquisition of goods;
  • TD19 – Invoice integration or self-invoicing for the purchase of goods from non-residents (ex art.17 c.2 DPR 633/72).

Following this extension of the document type codes, it will therefore be possible to issue a specific electronic document for the application of the reverse charge procedure through invoice integration relating to intra-EU and foreign purchases with the consequent possibility of exemption from the obligation to present the so-called “Esterometro”-declaration.
With regard to transactions carried out by usual exporters as well as those concerning VAT depots/consignment stocks, the following “Type of documents” codes should be noted:

  • TD21 - Self-billing for regularisation of exceeding the plafond;
  • TD22 - Extraction of goods from VAT depots;
  • TD23 - Extraction of goods from VAT depots with VAT payment.

As for deferred invoices, TD24 codes have been introduced for supplies of goods documented by delivery note or properly documented services, or TD25 in the case of internal triangulations.
Finally, specific codes have been provided for sales of fixed assets and internal transfers (TD26) and for invoices for self-consumption or for assignments free of charge or gifts (TD27).
The following table compares the codes of the previous version with those of the new version.



New Nature of transactions codes

As regards the "Nature” of the transactions, new subcodes have been introduced with reference to transactions not subject to VAT (N2), not taxable (N3) and transactions subject to reverse charge (N6). Therefore, from 1 January 2021, invoices or notes of variation can no longer be sent with the codes N2, N3 and N6 but only with one of the codes and new subcodes illustrated below.



New types of withholding tax and social contribution

The new specifications also introduce new codes in relation to the applicable type of withholding tax, in order to allow also the representation of social security contributions:



Further modifications

The other new features introduced by the technical specifications version 1.6.1 concern the introduction of the type of payment (“ModalitaPagamento”) code MP23 for the identification of transactions carried out through so called PagoPA, while for invoices or change notes subject to stamp duty the amount of stamp duty (“ImportoBollo”) becomes optional.
In the light of these changes, it is advisable to update the accounting and billing software to version 1.6.1 of the technical specifications as soon as possible in order to avoid any problems with the implementation of the files during the “transition” period and to adapt in good time to the new obligation.

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