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Value added tax

Second-quarter VAT settlement return due by 30 September: filing late within 15 days halves the penalty

Update. The penalty is halved only for returns filed by Thursday 15 October 2026; from 16 October, voluntary correction (ravvedimento) is calculated on the 500 euro penalty.

Wednesday 30 September 2026 is the deadline for filing the return on periodic VAT settlements for April, May and June. A missing, incomplete or inaccurate return carries a penalty of EUR 500 to 2,000, but the penalty is halved if the return is filed or corrected by Thursday 15 October, and voluntary correction (ravvedimento operoso) reduces it to a few tens of euros. The remedy changes if the annual VAT return has been filed in the meantime or if the VAT shown in the settlement has not been paid.

28 September 2026By Studio Ponchio11 min read

By Wednesday 30 September 2026, VAT taxable persons must send the Italian Revenue Agency (Agenzia delle entrate) the return on periodic VAT settlements (comunicazione delle liquidazioni periodiche IVA, known as LIPE) for the second quarter of 2026: the months of April, May and June for taxpayers who settle VAT monthly, the quarter as a whole for those who settle quarterly. The deadline is set by Article 21-bis(1) of Decree-Law No 78 of 31 May 2010; 30 September 2026 is a working day and, as at 28 September, no extension has been announced. Failing to file the return, or filing it with incomplete or inaccurate data, is subject to a penalty of EUR 500 to 2,000 (Article 11(2-ter) of Legislative Decree No 471 of 18 December 1997). The penalty is halved if the return, or a corrected return, is filed within fifteen days of the deadline: for the second quarter, by Thursday 15 October 2026.

What is reported and who is not required to file

The return summarises the accounting data of the periodic VAT settlements carried out in the quarter: sales and purchases, output VAT and input VAT deducted, VAT payable or VAT credit, and credits carried forward from previous periods. It must be filed even when the settlement shows a credit; taxable persons keeping separate accounts file a single summary return for each period. The LIPE does not change payment deadlines, which remain the ordinary ones: payments are not reported in the VP section of the form, including late payments made under voluntary correction.

The obligation does not apply to taxable persons who are not required to file the annual VAT return, or to those not required to carry out periodic settlements, provided that the conditions for relief from the obligation continue to be met throughout the year (Article 21-bis(3)). The relief therefore covers taxpayers who have no filing obligation, such as those carrying out exempt transactions only, within the limits of Article 8 of Presidential Decree No 322 of 22 July 1998, and, for the same reason, taxpayers under the flat-rate regime (regime forfetario), who neither settle VAT nor file the annual return.

According to the Revenue Agency’s instructions, there is also no obligation when there are no data to report for the quarter because no sales or purchases were carried out or recorded. The obligation does apply, however, if a credit from the previous period has to be carried forward: an “empty” quarter with a credit to carry forward must be reported.

How the return is filed

The return may only be filed electronically, either directly or through an authorised intermediary, using the form approved by the Revenue Agency as updated by the decision (provvedimento) of 14 March 2024. The file must be signed and can be sent through the Agency’s “Fatture e Corrispettivi” portal or its electronic filing channels; the filing receipt is available in the taxpayer’s secure online area. The 2024 decision brought the form into line with the minimum payment threshold for periodic VAT, raised to EUR 100: VAT payable not exceeding this threshold is paid together with the VAT for the following period, and in any event by 16 December of the same year, but it must always be shown in the return.

Missing, incomplete or inaccurate: the cost

The penalty under Article 11(2-ter) applies to each return that is missing or incorrect. Its amount depends on when the situation is remedied:

  • within 15 days of the deadline (for the second quarter of 2026, by 15 October) the penalty ranges from EUR 250 to 1,000;
  • after that date the full range of EUR 500 to 2,000 applies.

The halved penalty applies both to taxpayers who file a missing return late and to those who, within the same period, file a correct return replacing an incorrect one.

Voluntary correction

The breach can be regularised through voluntary correction under Article 13 of Legislative Decree No 472 of 18 December 1997, as the Revenue Agency clarified in resolution No 104/E of 28 July 2017; Article 21-bis itself, in paragraph 5, expressly refers to voluntary correction. The taxpayer files the missing or corrected return and at the same time pays the reduced penalty. No tax or interest is payable, since the return does not in itself give rise to a tax liability. For breaches committed from 1 September 2024, the reduction fractions and time limits of Article 13 as reworded by Legislative Decree No 87 of 14 June 2024 apply (Article 5 of that decree governs commencement). The basis of the calculation depends on when the return is filed: EUR 250 if it is filed by 15 October 2026, EUR 500 if it is filed later. The fraction of the reduction depends instead on when the penalty is paid. For the second-quarter 2026 return:

  • payment by 29 December 2026 (within ninety days of the deadline): one ninth, that is, EUR 27.78 on a EUR 250 basis, EUR 55.56 on a EUR 500 basis;
  • payment from 30 December 2026 to 30 April 2027 (the deadline for filing the annual VAT return for 2026): one eighth, that is, EUR 31.25 on a EUR 250 basis, EUR 62.50 on a EUR 500 basis;
  • payment after 30 April 2027: one seventh, that is, EUR 35.71 on a EUR 250 basis, EUR 71.43 on a EUR 500 basis.

The tables contained in the 2017 resolution still show the fractions and time limits in force before the 2024 reform: for breaches committed after the reform, the fractions now in force must be used.

Voluntary correction is no longer available once a tax demand or assessment has been served, including a notice of irregularity (comunicazione di irregolarità) under Article 54-bis of Presidential Decree No 633 of 26 October 1972 (Article 13(1-ter) of Legislative Decree No 472 of 1997). The compliance letters that the Agency sends when it detects inconsistencies do not bar it: Article 21-bis(5) provides for them precisely so that the taxpayer can explain the discrepancy or regularise the position.

Correcting before or after the annual return

Until the annual VAT return has been filed, an error is corrected by filing a new return for the same period: the latest return filed replaces the earlier ones. If the error comes to light after the annual return has been filed, or the annual return is filed in the meantime, the LIPE need not be refiled: the correction is made directly in the annual return, which supersedes the periodic return. As regards penalties, according to resolution No 104/E:

  • if the annual return shows the correct data, only the penalty for the incorrect LIPE is due, and it can be reduced through voluntary correction;
  • if the annual return is also wrong, a supplementary return (dichiarazione integrativa) must be filed, and the penalty for an inaccurate annual return (dichiarazione infedele) under Article 5(4) of Legislative Decree No 471 of 1997 also applies; this penalty, too, can be reduced through voluntary correction.

Correct return, VAT not paid

The position is different for a taxpayer who files an accurate return but does not pay the VAT shown in it. In that case there is no LIPE breach but a failure to pay: the penalty is 25 per cent of the unpaid tax, halved if the delay does not exceed ninety days and, for delays of up to fifteen days, further reduced to one fifteenth for each day of delay (Article 13(1) of Legislative Decree No 471 of 1997). Under voluntary correction, the taxpayer pays the tax, statutory interest and the reduced penalty: for example, where EUR 10,000 of VAT is paid 76 days late under voluntary correction, the penalty is EUR 138.89, that is, one ninth of 12.5 per cent, plus interest.

The LIPE is precisely the tool the Agency uses to match settlements against payments. If the liability remains unpaid, the taxpayer first receives a compliance letter and then, failing regularisation, the notice of irregularity issued under the early check provided for by Article 54-bis(2-bis) of Presidential Decree No 633 of 1972. From that point voluntary correction is barred: the amount is paid within sixty days with the penalty reduced to one third, that is, 8.33 per cent of the tax, or payment by instalments is requested. Failure to pay VAT is a criminal offence only if the tax due on the basis of the annual return exceeds EUR 250,000 per tax period, remains unpaid on 31 December of the year following the year in which the annual return is filed (for 2026 VAT, 31 December 2028) and is not being settled in instalments; if the taxpayer forfeits the instalment plan, the offence arises where the outstanding debt exceeds EUR 75,000 (Article 10-ter of Legislative Decree No 74 of 10 March 2000). What counts, therefore, is the annual total, not the individual settlement.

Points to watch

  • Where several returns are missing, the penalty in principle applies to each of them. For breaches committed from 1 September 2024, however, Article 12 of Legislative Decree No 472 of 1997 extends the single combined penalty (cumulo giuridico) to repeated breaches of the same provision, except those relating to payment obligations and undue offsetting (paragraph 1), and expressly allows it under voluntary correction as well, separately for each tax, tax period and dispute-avoidance procedure (istituto deflativo) (paragraph 8); the reduction is then determined by reference to the first breach (Article 13(2-bis)). The single penalty may in no case exceed the sum of the penalties for the individual breaches (Article 12(7)). Ruling No 450 of 2023, which excluded the combined penalty under voluntary correction, concerns the previous rules. A taxpayer who has failed to file several LIPE returns in the same year can therefore compare the sum of the penalties reduced for each return with the reduced single penalty; the combined penalty does not apply, by contrast, to failures to pay VAT.
  • A quarter with no transactions but with a credit to carry forward is not relieved of the filing obligation.
  • From 1 January 2027, when the new consolidated codes take effect, the rules will be moved into them. Article 21-bis becomes Article 51 of the consolidated code on tax compliance and assessment (Legislative Decree No 141 of 5 August 2026), and the penalty moves to Article 36(4) of the consolidated code on tax penalties (Legislative Decree No 173 of 5 November 2024), with the same amounts. The rules currently in force apply to the second-quarter 2026 return.

In practice

  • By 30 September 2026, file the second-quarter LIPE, even if it shows a credit, and keep the filing receipt.
  • Before filing, check that the data match the VAT registers and the payments for the quarter, including VAT of up to EUR 100 carried forward to the following period.
  • If the deadline has been missed, file the return by 15 October 2026 and pay the reduced penalty of EUR 27.78 with form F24 by 29 December 2026 (EUR 31.25 if payment is made by 30 April 2027).
  • If an error is discovered, file a replacement return before the annual VAT return is filed; afterwards, make the correction in the annual return.
  • If the VAT shown in the settlement has not been paid, regularise it through voluntary correction before a notice of irregularity arrives.
  • Check the taxpayer’s online tax file (Cassetto fiscale) and the “Fatture e Corrispettivi” portal regularly, since the Agency delivers its compliance letters there.
  • In the case of voluntary correction, keep the filing receipt for the return, the F24 form for the penalty and a calculation sheet showing the filing date, the basis (EUR 250 or 500) and the fraction applied.

Frequently asked questions

If I carried out no transactions in the quarter, do I have to file the LIPE?

No, if there are no data to report for the quarter and there is no credit from the previous period to carry forward. If there is a credit to carry forward, the return must be filed even if no transactions were carried out.

I filed the LIPE with an error: can I correct it after 30 September?

Yes. A corrected return filed by 15 October 2026 halves the penalty to EUR 250, which voluntary correction reduces to EUR 27.78 if the penalty is paid by 29 December 2026 (EUR 31.25 by 30 April 2027). If the corrected return is filed after 15 October, the basis returns to EUR 500, and voluntary correction remains available. If the annual VAT return is filed in the meantime, the correction is made directly in that return.

If I do not pay the VAT shown in the LIPE, is the penalty the same?

No. A correct return that is not followed by payment does not breach the reporting obligation: the penalty for failure to pay applies, at 25 per cent of the tax (12.5 per cent if the delay does not exceed ninety days), and it can be reduced through voluntary correction until a notice of irregularity arrives.

Sources

Article 21-bis of Decree-Law No 78 of 31 May 2010, converted by Law No 122 of 30 July 2010.

Articles 5(4), 11(2-ter) and 13 of Legislative Decree No 471 of 18 December 1997.

Articles 12 and 13 of Legislative Decree No 472 of 18 December 1997; Article 5 of Legislative Decree No 87 of 14 June 2024.

Article 54-bis(2-bis) of Presidential Decree No 633 of 26 October 1972; Article 2 of Legislative Decree No 462 of 18 December 1997; Article 3 of Legislative Decree No 108 of 5 August 2024.

Article 8 of Presidential Decree No 322 of 22 July 1998; Article 1(4) of Presidential Decree No 100 of 23 March 1998, as amended by Article 9 of Legislative Decree No 1 of 8 January 2024.

Article 10-ter of Legislative Decree No 74 of 10 March 2000.

Legislative Decree No 141 of 5 August 2026 (Article 51 of the consolidated code); Legislative Decree No 173 of 5 November 2024 (Article 36 of the consolidated code).

Agenzia delle entrate: resolution No 104/E of 28 July 2017; ruling No 450 of 2023; decision of 14 March 2024, ref. No 125654, and instructions for the periodic VAT settlement return form; tax calendar.

This article reflects the legislation and administrative guidance in force at the date of publication and is no substitute for an assessment of the individual case: reconstructing the settlements, choosing between a replacement return and a correction in the annual return, calculating penalties where there are several breaches and regularising payments all require a specific analysis of the taxpayer’s position.

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