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Consolidated VAT code from 2027: what changes for invoicing

From 2027 VAT moves to Legislative Decree 10/2026: same rules, new articles, paragraphs and letters. What to update in software, invoices and contracts.

From 1 January 2027 the VAT rules are to be found in the testo unico IVA (consolidated VAT code) approved by Legislative Decree no. 10 of 19 January 2026, and no longer in Presidential Decree (d.P.R.) 633/1972. Rates and mechanisms remain those in force today, with a few changes, such as the thresholds for simplified invoicing by contribuenti minori (smaller taxpayers, Article 93). The deadlines already in place also remain: unless extended, the reverse charge for mobile phones, game consoles, tablets, laptops and microprocessors, emission allowances and certificates, and gas and electricity supplied to resellers applies only to transactions carried out up to 31 December 2026 (Article 64, paragraph 8; currently Article 17, paragraph 8, of d.P.R. 633/1972). What changes is the numbering of the articles and, often, of paragraphs and letters as well. Until 31 December 2026 d.P.R. 633/1972 continues to apply; for those who issue invoices, the work to be done now is to update VAT codes, invoice wording and contracts.

The framework

Legislative Decree no. 10 of 19 January 2026 (Official Gazette no. 24 of 30 January 2026, ordinary supplement no. 4) was adopted under Article 21, paragraph 1, of Law 111/2023, the enabling law for the reorganisation of tax legislation into consolidated codes. The decree has been in force since 31 January 2026, but Article 171 of the consolidated code sets its application from 1 January 2027. Today invoices, periodic VAT settlements and returns still follow d.P.R. 633/1972, Decree-Law 331/1993 for intra-Community trade and various other laws.

The consolidated code has 171 articles. It is a reorganisation: each article indicates in brackets the provisions from which it derives, and it also contains rules that previously sat outside the VAT decree, such as the margin scheme (Articles 143 et seq.) and the e-invoicing obligation (Article 77). From the date on which the consolidated code applies, Article 170 repeals the original provisions; paragraph 3 provides that references in laws, regulations and administrative measures to the repealed provisions are to be read as references to the new articles. The implementing regulations, such as d.P.R. 100/1998 on periodic VAT settlements, and the rules on audits and assessments remain outside the consolidated code.

What changes in concrete terms

The calculation rules stay the same. A business with 300,000 euro of taxable transactions and 100,000 euro of exempt transactions has a deductible pro rata of 75% (300,000 divided by 400,000); out of 20,000 euro of input VAT it deducts 15,000, today under Articles 19 and 19-bis of d.P.R. 633/1972, and from 2027 under Articles 56 and 57 of the consolidated code. The standard rate remains 22% (Article 34). What does change, however, are the thresholds for simplified invoicing and bookkeeping by smaller taxpayers: from 400,000 to 500,000 euro for services and from 700,000 to 800,000 euro for other activities (Article 93, currently Article 32 of d.P.R. 633/1972).

With the article number, the paragraph and the letter often change too. A cleaning company that invoices 12,000 euro to another business for cleaning a building applies the reverse charge: the customer supplements the invoice with 2,640 euro of VAT. Today the provision is Article 17, paragraph 6, letter a-ter), of d.P.R. 633/1972; from 2027 it becomes Article 64, paragraph 6, letter c), of the consolidated code. The same applies to the esportatore abituale (habitual exporter) purchasing under a dichiarazione d’intento (declaration of intent): Article 8, paragraph 1, letter c), becomes Article 45, paragraph 1, letter d).

Topic	Until 31/12/2026	From 1/1/2027 (Legislative Decree 10/2026)
Place of supply of services	Article 7-ter d.P.R. 633/1972	Article 17
Taxable amount	Article 13	Article 27
Exempt transactions	Article 10	Article 37
Exports and habitual exporters	Article 8	Article 45
Intra-Community supplies	Article 41 Decree-Law 331/1993	Article 39
Deduction and pro rata	Articles 19 and 19-bis	Articles 56 and 57
Domestic reverse charge	Article 17, paragraphs 5 and 6	Article 64, paragraphs 5 and 6
Split payment	Article 17-ter	Article 65
Invoice and simplified invoice	Articles 21 and 21-bis	Articles 72 and 73
Variation notes (credit and debit notes)	Article 26	Article 92
Margin scheme	Article 36 Decree-Law 41/1995	Article 143

On invoices, particular care must be taken over the wording. Article 72, paragraph 6 (currently Article 21, paragraph 6), requires the annotations “operazione non imponibile” (zero-rated transaction), “operazione esente” (exempt transaction) and so on, with an “optional” reference to the relevant provision: the wording is mandatory, the article number is not, but if it is stated it must be the correct one. Those applying the regime forfettario (flat-rate scheme) currently cite Article 1, paragraphs 54 to 89, of Law 190/2014: from 2027 the VAT franchise (small-business exemption) is in Article 157 of the consolidated code, which refers to the testo unico delle imposte sui redditi (consolidated income tax code, Legislative Decree no. 117 of 19 June 2026).

In practice

• By 31 December 2026, the accounts department, together with the provider of the accounting software, prepares the table of VAT codes with the new descriptions, valid for transactions carried out from 1 January 2027, checking the article, paragraph and letter of each code.
• For transactions carried out up to 31 December 2026, references to d.P.R. 633/1972 remain, even if the invoice is issued in January 2027, for example the deferred invoice for December deliveries. This is the reading consistent with the time at which the transaction is deemed to take place (Article 24 of the consolidated code, currently Article 6); as of November 2026 no specific official guidance has been issued.
• Invoice templates, general terms and conditions, price lists and existing contracts should be reviewed: the automatic cross-reference in Article 170, paragraph 3, covers laws, regulations and administrative measures, not contracts. In new contracts it is advisable to cite the new provision, or both.
• The correlation table should be dated and kept with the accounting records: in the event of an audit, it explains the choices made on the codes.

Mistakes to avoid

• Changing only the article number and leaving the old letter: for the reverse charge, letter a-ter) becomes c); for exports, letter c) becomes d).
• Citing the consolidated code for transactions of 2026 or earlier years, including in a reply to an audit.
• Using the text published in the Official Gazette in January: some articles have already been amended, Article 170 for example by Legislative Decree no. 141 of 5 August 2026. The updated version must be consulted.
• Looking in the consolidated code for rules that are not there, such as the rules on assessment or the implementing regulations.

References

Legislative Decree no. 10 of 19 January 2026 (Official Gazette no. 24 of 30/1/2026, ordinary supplement no. 4), consolidated VAT code, Articles 17, 24, 27, 34, 37, 39, 45, 56, 57, 64, 65, 72, 73, 77, 92, 93, 143, 157, 170 and 171

d.P.R. no. 633 of 26 October 1972, Articles 6, 7-ter, 8, 10, 13, 17, 17-ter, 19, 19-bis, 21, 21-bis, 26 and 32

Decree-Law no. 331 of 30 August 1993, Article 41

Decree-Law no. 41 of 23 February 1995, Article 36

Law no. 111 of 9 August 2023, Article 21

Law no. 190 of 23 December 2014, Article 1, paragraphs 54-89

Legislative Decree no. 117 of 19 June 2026 (consolidated income tax code)

Legislative Decree no. 141 of 5 August 2026 (consolidated code on tax compliance and assessment)

Legislative Decree no. 472 of 18 December 1997, Article 3

Legislative Decree no. 173 of 5 November 2024, Article 2 (provisions applicable from 1 January 2027)

d.P.R. no. 100 of 23 March 1998

Directive 2006/112/EC