Starting from January 1, 2025, Article 1, paragraph 21 of Law no. 207 of December 30, 2024 (“2025 Budget Law”), removes the 5.5 million digital services revenues threshold. Accordingly, both residents and non-residents entities with (even consolidated) revenues (anywhere realized) exceeding 750 million euros may be subject to the Italian digital services tax (“IDST”) in Italy at a rate of 3% for any consideration derived for the provision of digital services (such as channelling or hosting targeted advertising, intermediation services of goods and services (e.g., marketplace), social networks, and data transmission) at Italian users through digital interfaces (websites, apps, etc.).
Furthermore, while previously the payment of the IDST due for the reference calendar year was postponed and unified to May 16 of the following calendar year, the 2025 Budget Law introduces an advance payment due by November 30 for an amount of 30% of the IDST due for the calendar year preceding the reference calendar year, and the remaining balance by May 16 of the calendar year following the reference calendar year. On the other hand, the deadline of June 30 of the following calendar year for submitting the IDST Return remains unchanged.
In 2025, therefore, there is a double deadline for the IDST payment: (i) for the calendar year 2024, the IDST is due by May 16, and (ii) for the calendar year 2025, the IDST advance payment is due by November 30, 2025, equalling to the 30% of the IDST due for the calendar year 2024 (the IDST balance is due by May 16, 2026).
The removal of the digital revenue threshold of 5.5 million euros clearly significantly increases the number of the digital business (e.g., social media, marketplaces, transmission of data service providers, targeted advertising services provider etc.) exposed to IDST. In this regard, any digital business that in past years did not pay enough attention to the IDST because their digital services revenue amounts were below the 5.5 million euros threshold are now called upon to carefully assess their operations as they could possibly be subject to the IDST.
