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  5. EU VAT Refund 2025: September 30, 2026 Deadline for Foreign Companies

EU VAT Refund 2025: September 30, 2026 Deadline for Foreign Companies

EU VAT Refund 2025: September 30, 2026 Deadline for Foreign Companies

Updated September 10, 2026

If your company paid VAT in Italy or in another EU country during 2025, you may still be entitled to recover it.

The key date is:

September 30, 2026

This is the deadline for submitting many EU VAT refund claims relating to VAT paid during 2025.

For foreign companies, the issue is often overlooked. VAT paid on trade fairs, hotels, local services, rentals, fuel, business purchases or imports may remain buried in accounting records and become a permanent cost simply because no refund claim is filed.

For businesses operating internationally, reviewing foreign VAT is therefore not just a tax compliance exercise. It can be a direct way to recover cash.

Can a foreign company recover VAT paid in Italy?

In many cases, yes.

A company established in another EU Member State may be able to recover Italian VAT paid on eligible purchases and imports, provided that the conditions set out under EU and Italian VAT rules are met.

The same principle applies in reverse to Italian companies that paid VAT in another EU country.

The procedure is governed mainly by Directive 2008/9/EC and, under Italian law, by the relevant VAT refund provisions contained in Presidential Decree No. 633/1972.

What types of expenses should be reviewed?

Foreign companies should check whether they paid local VAT in 2025 on expenses such as:

  • trade fairs and exhibitions;
  • hotel accommodation;
  • business travel;
  • vehicle rental;
  • fuel;
  • local professional services;
  • purchases of goods;
  • imports;
  • other costs directly connected with business activity.

Not all VAT is automatically refundable.

The right to recovery depends on the nature of the expense and on the VAT deduction rules applicable in the country where the tax was paid.

This means that the correct approach is not simply to total all foreign VAT invoices. Each expense must be reviewed based on the local VAT rules.

What is the deadline for 2025 VAT refund claims?

For VAT incurred during 2025, the refund application must generally be filed by:

September 30, 2026

Under Directive 2008/9/EC, the application must be submitted no later than September 30 of the calendar year following the refund period.

This deadline should be treated seriously because late filing may result in the loss of the refund right.

Companies should therefore avoid waiting until the final days of September.

Missing invoices, incorrect VAT details, incomplete supporting documents or transmission issues may create unnecessary problems at the last minute.

How does the EU VAT refund procedure work?

For a business established in one EU Member State that paid VAT in another EU Member State, the refund application is generally submitted electronically through the tax authority of the country where the company is established.

The tax authority then forwards the application to the Member State where the VAT was paid.

That Member State examines the claim according to its own VAT deduction and refund rules.

For example, a German company seeking a refund of Italian VAT would normally submit the claim through the German electronic procedure, while the Italian tax authorities would assess whether the Italian VAT is refundable.

Can a US or UK company recover Italian VAT?

Non-EU companies may also be entitled to recover Italian VAT in certain circumstances, but the applicable procedure and conditions can differ from those applying to EU-established businesses.

The analysis becomes particularly important where the company has:

  • an Italian VAT registration;
  • a fiscal representative in Italy;
  • a branch or permanent establishment;
  • recurring business activity in Italy;
  • imports into Italy;
  • sales subject to Italian VAT.

In these situations, the refund procedure should be assessed carefully before submitting any claim.

Does having an Italian VAT number prevent a refund?

Not necessarily.

The mere existence of an Italian VAT registration does not always automatically prevent the use of a refund procedure.

However, it is essential to determine:

  • how the Italian VAT number has been used;
  • whether taxable transactions were carried out in Italy;
  • whether purchase invoices were recorded through the Italian VAT position;
  • whether the VAT was already included in Italian VAT returns or periodic VAT settlements.

A company should therefore avoid assuming that a local VAT number automatically excludes a refund, or that it automatically allows one.

The actual transactions matter.

What if the foreign company has a branch in Italy?

The presence of a branch or permanent establishment requires particular attention.

Under EU principles, the existence of a fixed establishment in the refund country does not necessarily settle the matter by itself.

It is also relevant to determine whether that establishment actually carried out taxable transactions in the country during the refund period.

This distinction can be important for international groups that maintain a branch in Italy but conduct only limited or specific activities through it.

In these cases, a factual review is often necessary before excluding the possibility of a VAT refund.

What are the minimum refund amounts?

Under Directive 2008/9/EC, the minimum refund thresholds are generally:

  • EUR 400 for a claim covering a period shorter than one calendar year but not shorter than three months;
  • EUR 50 for a claim covering a full calendar year or the remaining part of the year.

This means that even relatively small VAT amounts may be worth reviewing.

For businesses with recurring activity in several countries, small VAT amounts can become significant over time.

Can supporting invoices be requested?

Yes.

The refund Member State may require copies of invoices or import documents, particularly where the taxable amount exceeds certain thresholds.

Under EU rules, supporting documentation may be requested where the taxable amount shown on the invoice or import document is at least:

  • EUR 1,000;
  • EUR 250 for fuel-related invoices.

Additional information may also be requested where the tax authority needs further evidence before approving the refund.

Good documentation therefore matters.

How long does the VAT refund take?

In ordinary cases, the refund Member State should notify the applicant of its decision within four months from receipt of the application.

Where additional information is requested, the procedure may take longer.

Depending on the circumstances, the final decision may be issued within up to eight months.

A well-prepared claim can reduce the risk of delays and additional information requests.

What if the electronic filing system fails?

A recent EU Court of Justice decision is particularly relevant.

On March 12, 2026, in Case C-527/24, the Court addressed a situation involving a VAT refund request affected by a technical malfunction in the electronic submission process.

The Court held, in substance, that a taxpayer should not automatically lose the VAT refund right solely because the electronic system failed and the application could not formally be treated as submitted.

This is an important safeguard.

However, companies should still file well before the deadline and retain evidence of any technical issue.

Example: foreign company attending trade fairs in Italy

Consider a foreign company attending several trade fairs in Italy during 2025.

It pays Italian VAT on:

  • exhibition-related services;
  • local purchases;
  • transportation;
  • accommodation;
  • equipment rental;
  • other business expenses.

At the end of the year, the company has paid EUR 12,000 of Italian VAT.

If the conditions for recovery are satisfied, that EUR 12,000 may represent recoverable cash rather than a permanent business cost.

If nobody reviews the invoices and no refund application is filed, the company may simply lose the opportunity.

Why a tax advisor should review foreign VAT before filing

Submitting the electronic application is only one part of the process.

Before filing, a professional review should consider:

  • whether the VAT is recoverable;
  • whether the expense is connected with the business;
  • whether the invoice is formally correct;
  • whether local VAT deduction restrictions apply;
  • whether the company has a VAT registration in the refund country;
  • whether it has a branch or permanent establishment;
  • whether taxable transactions were carried out locally;
  • whether another VAT recovery procedure should be used instead.

This is where an experienced tax advisor can add real value.

A good tax advisor should not simply process forms. He should identify opportunities, prevent procedural mistakes and help the client choose the most appropriate route to recover tax efficiently and safely.

Foreign company doing business in Italy? Check your 2025 VAT now

If your company incurred Italian or EU VAT during 2025, September is the right time to review the documentation.

Studio Cavallari assists foreign and international companies with Italian VAT, accounting and cross-border tax matters.

We can review the invoices, assess eligibility and assist with the appropriate VAT recovery procedure.

This service may be particularly relevant for:

  • US companies doing business in Italy;
  • UK companies operating in Italy;
  • German, Austrian and other EU companies;
  • international groups;
  • companies attending trade fairs in Italy;
  • companies with Italian VAT registrations;
  • companies using fiscal representatives;
  • businesses with branches or permanent establishments in Italy.

September 30, 2026 is approaching. A timely review may prevent recoverable VAT from becoming a permanent cost.

Italian VAT and International Tax Assistance

Studio Cavallari – Italian Tax Advisor

Phone: +39 049 613584
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The first introductory call can be free of charge and is intended to determine whether your situation requires a more detailed review.

Dr. Massimo Cavallari
Italian Chartered Accountant with over 25 years of experience, registered under No. 932/A Padova and Expert Contributor to Il Sole 24 Ore.

Frequently Asked Questions

Can a foreign company recover Italian VAT paid in 2025?

Yes, in many cases, provided that the applicable EU and Italian VAT refund conditions are satisfied.

What is the deadline for recovering VAT paid in 2025?

The relevant deadline for many EU VAT refund claims is September 30, 2026.

Can a company recover VAT paid on hotels and trade fairs in Italy?

Potentially yes, but the deductibility of each expense must be reviewed under Italian VAT rules.

Does an Italian VAT registration prevent the refund?

Not automatically. The transactions carried out through that VAT registration and the treatment of purchase invoices must be examined.

Can a company with an Italian branch obtain a VAT refund?

Possibly. The analysis should consider whether the branch actually carried out taxable transactions in Italy during the refund period.

Can non-EU companies recover Italian VAT?

In some cases yes, although the applicable rules and procedures may differ from those available to EU-established companies.

What is the minimum VAT refund amount?

Generally EUR 400 for certain interim claims and EUR 50 for annual or final-period claims.

Should a company wait until September 30 to file?

No. Filing earlier is advisable because missing documents, formal errors or technical transmission problems may require time to resolve.

Official Sources

European Union, Directive 2008/9/EC, VAT refund procedure for taxable persons established in another Member State.

Italian VAT Law, Presidential Decree No. 633/1972, including Articles 38-bis1, 38-bis2 and related provisions.

Italian Revenue Agency, guidance and electronic procedures concerning VAT refunds.

Court of Justice of the European Union, Case C-527/24, judgment of March 12, 2026.