Articolo pubblicato su FiscoOggi (

Tax Pills

  • Heads of 46 tax administrations met in Australia


    The 15th Plenary meeting of the Oecd Forum on Tax Administration (FTA) has been held at Sidney from 28 to 30 September 2022. The conference, attended by the Oecd Secretary General, Mathias Cormann, marked the 20th anniversary since the formation of the FTA in 2002 and was the first in-person meeting of FTA Commissioners at Plenary since March 2019. The meeting has brought together Commissioners from advanced and emerging tax administrations from across the globe and representatives from international organisations and regional tax administration bodies. On behalf of the Italian Revenue Agency were the deputy director of the revenue and head of the tax-collection division, Paolo Valerio Barbantini, and the head of the agency's international sector, Francesca Vitale.

    Topics at issue - At this year’s Plenary, the heads of tax administrations, together with business representatives, have discussed potential future challenges and opportunities, including those arising from the rapid digitalisation of the economy. Has been also had in-depth discussions on the three key areas agreed to maintain as priorities for the coming period, namely: the implementation of the Two-Pillar Solution to address the tax challenges arising from the digitalisation of the economy, including the need for streamlined tax certainty processes; the ongoing digital transformation of tax administrations in support of a more seamless model for taxation; and further tax capacity building to support developing country tax administrations.

    What news – Particularly, on the Two-Pillar Solution the Commissioners agreed to exploring the use of new technology tools to help deliver common solutions in order to reduce burdens for both our administrations and for business. Heads of tax administrations has also decided to identify improvements to the APA Process, as set out in the Bilateral Advance Pricing Arrangement Manual published at the Plenary, through exploring opportunities for further training and capacity building. Moreover, in line with future visions of seamless tax administration, Tax Administration 3.0, the representatives agreed a new strategic framework to govern the second phase of collaboration, involving the creation of a new senior-level expert working group, open to all our members, as well as closer working with key external stakeholders through the establishment of a new advisory group on digital transformation. In the context of the cross-border exchange of information related to sharing and gig economy platforms, the assembly also discussed the possibility of launching an innovative pilot project based on the automated mutual recognition of digital identities in use in different countries.
    As far as the capacity building is concerned, at the forum has been agreed to increase the practical support provided by work of the FTA Capacity Building Network, particularly strengthening the digitalisation of developing country tax administrations, and to renew the commitment in Tax Inspectors Without Borders (TIWB) pilot programme focused on digitalisation challenges, in partnership with the United Nations Development Programme.

    Finally, the 2023 and 2024 Plenaries will be hosted in Singapore and Greece respectively.

    Stefano Latini

  • 5% Vat rate also for ancillary services related to the supply of natural gas


    Supply of natural gas for combustion, for civil or industrial use, will benefit of a reduced rate of 5% for the entire amount of the gas-bill, including systemic and ancillary charges. With Resolution n. 47 of 6 September 2022, the Italian Revenue Agency has returned on the measure introduced on a temporary basis to mitigate the effects of the increase in electricity and gas prices, providing further clarifications.
    Therefore is correct to notice how this further clarification actually follows and partially rectifies the clarifications already given with the response to the ruling n. 368/2022, concerning article 2 of the Law Decree n. 130 of September 27, 2021, so called “Taglia bollette”, which in order to mitigate the soaring costs of gas provides, as a temporary and emergency measure, the application of the 5% VAT rate for the supply of natural gas used for combustion for civil and industrial uses. Indeed, the fiscal relief has been extended several times and, recently, the 'Aid' decree prolonged the measure until the third quarter of 2022.

    Why the 5% Vat rate has a larger application – As recalled by the Resolution n. 47, the objective of the measure explained by the illustrative report is to stem the negative effects of the increase in gas for civil and industrial uses by introducing, as a temporary derogation to ordinary taxation, the rate of 5 per cent for supplies at rates of 10 per cent and 22 per cent. The favourable treatment, the technical report specifies, is applicable regardless of the consumption bracket.
    That said, the Agency clarifies that paragraph 1 of Article 2 of the Decree, which introduces the cut in VAT, should be read in conjunction with the subsequent paragraph 2, which refers to the Regulatory Authority for Energy, Networks and Environment, the task of reducing the rates on general system charges. The same applies to Article 1-quater of the 'Aid' decree, which confirms the reduced rate for the third quarter of 2022 also in relation to ancillary charges.
    In short, the rationale of the favourable measure is to lighten the bill tolerated by end users as much as possible, without any differentiation of the rate for the different consumption brackets and without distinguishing the portion of gas consumption for civil uses exceeding the limit of 480 cubic metres. Consequently, the reduced rate of 5% must be applied to the entire "package" relating to the supply of natural gas and accounted for all the invoices issued during the period in which the temporary rule will remain in force.

    Stefano Latini