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VAT numbers · Documents

Credit notes and self-billed invoices

Credit notes and self-billing in Italy exist because an invoice once issued cannot be deleted or changed: it is corrected with a new document. The delicate point is the deadline, because after a certain moment the VAT can no longer be recovered.

01 · The correction

What a credit note is

It is the document used to reduce an invoice that has already been issued. It does not cancel the original invoice, which stays in place: it corrects it with a document of the opposite sign, which must also be sent through the Sistema di Interscambio (SdI, the Italian e-invoicing exchange system).

  • It is issued for invoicing errors: amount, VAT rate, customer details, quantity.
  • For discounts and allowances agreed after the invoice was issued.
  • For returned goods and services not performed.
  • For termination, withdrawal or cancellation of the contract.
  • For the customer's failure to pay, in the cases and within the time limits the rules provide.
  • The debit note is the mirror document, for upward corrections: it is issued like an ordinary invoice.
The key distinction is between corrections due to errors and corrections due to later events. The former have a one-year limit from the transaction for recovering the VAT; the latter, when they depend on the original agreements between the parties or on causes set out in the law, are not subject to that limit.
02 · When you can

The deadline for issuing a credit note

The deadline depends on the reason for the correction, and the consequence of being late is not that the document is void but that the VAT cannot be recovered.

  • After the deadline the credit note can still be issued, but without recovering the VAT.
  • The document must be sent through the SdI with the required document type.
  • It must be recorded in the sales or purchases register, as the case may be.
  • The customer who receives the credit note must adjust the VAT deduction already taken.
  • The credit note must quote the details of the original invoice.
Reason for the correctionDeadline for recovering the VAT
Invoicing errorOne year from the date of the transaction
A later agreement between the partiesOne year from the transaction
Nullity, annulment, termination, rescissionNo time limit
Allowances and discounts provided for in the contractNo time limit
Customer's insolvency proceedingsFrom the date set by law for each type of proceeding
Enforcement proceedings that failedFrom the date the failure is established
03 · The customer who doesn't pay

Recovering VAT on unpaid invoices

This is the case people care about most: you issued the invoice, you paid the VAT, the customer did not pay. The tax can be recovered, but only when specific conditions are met.

  1. Insolvency proceedings

    In judicial liquidation, a composition with creditors or other proceedings, the credit note can be issued from the date set by law for each proceeding, without waiting for it to close.

  2. Individual enforcement proceedings

    The enforcement must have failed: a seizure of goods with nothing found, a garnishment of third parties with no result.

  3. Debt restructuring agreements

    They allow the correction from the date of publication or court approval, depending on the case.

  4. Simple late payment

    Non-payment without any proceedings does not allow recovery: one of the conditions set out in the law must apply.

What to keep

Proof of the condition is everything.

  • A copy of the proof of claim filed in the proceedings, where applicable
  • The report of the unsuccessful seizure or the bailiff's statement
  • Court orders relating to the proceedings
  • Your reminder correspondence, which supports your good faith
Let's check the recovery
04 · Invoicing yourself

When a self-billed invoice is needed

The autofattura (self-billed invoice) is a document the VAT-registered person issues to themselves, in the cases where the law requires it. It is not an anomaly: it is how the tax is accounted for when there is no document from the supplier.

Purchases from foreign suppliers

For services received from non-EU suppliers you issue a self-billed invoice; for EU suppliers you supplement the invoice you received. See reverse charge.

Own use

Goods used for purposes unrelated to the business or for the personal use of the owner.

Gifts

Free transfers of goods the business deals in, under the applicable rules.

Regularisation

When the supplier does not issue the invoice on time, the customer must regularise the position with a self-billed invoice to avoid a penalty.

Internal transfers

Between activities of the same person that are kept separate for VAT purposes.

Removal from a VAT warehouse

Under the specific rules for that arrangement.

The self-billed invoice for regularisation is the one that protects the customer: if the supplier does not issue the invoice, a customer who does not act within the set time limit is penalised too. It is a safeguard few people know about, and worth remembering when a supplier is late.
05 · The codes

How credit notes and self-billed invoices are sent

In the electronic invoicing system, every document has a type code that determines how it is treated.

  • The credit note has its own document type, separate from the ordinary invoice.
  • The debit note is sent as an invoice, since it is an upward correction.
  • The self-billed invoice for purchases from non-EU suppliers and the supplement for EU suppliers have separate codes.
  • The self-billed invoice for regularisation has its own code, which tells the Agenzia delle Entrate (the Italian Revenue Agency) that the supplier has failed to invoice.
  • Own use and free transfers have their own code.
  • Using the wrong code creates mismatches in the databases, which come to light in automated checks.
06 · What to avoid

The most frequent mistakes

Almost all of them are about timing or using the wrong document.

  • Issuing the credit note after the deadline for invoicing errors, and losing the VAT recovery.
  • Deleting the invoice instead of correcting it: an invoice sent through the SdI cannot be removed.
  • Issuing a credit note for simple non-payment, without one of the required conditions applying.
  • Not regularising with a self-billed invoice when the supplier does not issue the document.
  • Using the wrong document type code in the electronic invoice.
  • Not quoting the details of the original invoice in the credit note.
A credit note issued for a customer who is simply late in paying, with no insolvency proceedings and no failed enforcement, is one of the most common findings. VAT recovered that way is reclaimed by the tax authorities with penalties: a bad debt, on its own, is not enough.
Frequently asked

The questions that keep coming up

I got an invoice wrong. Can I just redo it?

No. An invoice sent through the SdI cannot be deleted or changed: it must be corrected with a credit note that quotes its details, followed by a new, correct invoice.

Recovering VAT for invoicing errors has a limit of one year from the transaction: after that, the credit note can still be issued, but you bear the tax yourself.

A customer never paid me. Do I get the VAT back?

Only if the required conditions are met: insolvency proceedings against the customer, or individual enforcement proceedings that failed.

Simple late payment, however long, is not enough. You need documentary proof of the condition: the report of the unsuccessful seizure, orders in the proceedings, the proof of claim.

My supplier hasn't sent me the invoice. Am I at risk?

Yes. A customer who does not receive the invoice within the set time limits must regularise by issuing a self-billed invoice and paying the tax, otherwise they are penalised too.

It is a little-known but important safeguard: waiting for the supplier does not protect you. The time limit for acting is short and runs from the moment the invoice should have arrived.

I am on the flat-rate scheme. Do I have to issue self-billed invoices?

Yes, in the cases the law provides for: in particular for services received from non-EU suppliers, while for EU suppliers you supplement the invoice you received.

VAT accounted for in this way cannot be deducted under the regime forfettario (flat-rate scheme) and must be paid with an F24 (the Italian tax payment form): it is a real cost. It also applies to software subscriptions and online advertising, which are the most common items.

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The deadline for recovering VAT does not reopen

One year for errors, separate rules for unpaid invoices. Bring us the document as soon as you notice.