Italy’s Revenue Agency (Agenzia delle Entrate), in Response No. 111/2026, clarified the VAT treatment of a cross-border chain transaction involving a German intermediary, a Polish supplier, and an Italian customer. The case concerned goods transported directly from Poland to Italy by the German intermediary, which argued that the transaction qualified for the EU triangular simplification regime.

The Agency concluded that the transaction falls under the chain transaction rules introduced by the EU “Quick Fixes” and implemented in Italy through Article 41-ter of Decree-Law No. 331/1993. Because the German intermediary arranged the transport and provided its German VAT identification number to the Polish supplier rather than a Polish VAT number, the intra-Community transport is attributed to the supply made to the intermediary.

As a result, the subsequent sale by the German intermediary to the Italian customer is treated as a domestic Italian supply rather than a triangular simplification transaction. The Agency therefore held that the German company was required to register for VAT purposes in Italy.

The ruling confirms the application of the EU chain transaction rules to determine which supply in a chain benefits from intra-Community treatment and underscores that foreign intermediaries may incur Italian VAT registration obligations where the final sale is regarded as taking place in Italy.

Key takeaway: This is not primarily about triangular simplification; it is about chain supplies, transport attribution under Article 41-ter, and the resulting requirement for a non-resident intermediary to obtain an Italian VAT registration because its sale to the Italian customer is treated as a domestic Italian transaction.