Amazon, Guardia di Finanza searches for new tax evasion investigation
The line of investigation concerns an alleged 'hidden permanent establishment', as the multinational company allegedly operated and generated income in Italia
The Guardia di Finanza conducted searches at Amazon's Italian headquarters as part of a new investigation into alleged tax evasion of several hundred million between 2019 and 2023. This was reported by the Reuters news agency. The homes of seven executives of the e-commerce giant and the offices of the auditing firm Kpmg (which is not under investigation) were also searched. The Gdf seized, among others, computers and IT devices belonging to the executives, including hard-disks where employees' e-mails (deleted from Amazon's systems every three months) are stored.
The dispute
The investigation strand, now under investigation, is coordinated by public prosecutor Elio Ramondini. The charge concerns an alleged 'concealed permanent establishment' in that the multinational would have operated and generated income in Italia. The aim is to verify whether Amazon had an undeclared permanent establishment in Italia from 2019 to 2024, with the consequent effects that would be triggered from a tax point of view. The Milan Public Prosecutor's Office's hypothesis is that Amazon had a permanent establishment in Italia even before August 2024, i.e. when the group joined a 'co-operative compliance' programme with the Italian Revenue Agency and started paying taxes in our country.
Investigation strands
On Amazon, Prosecutor Ramondini with the Guardia di Finanza of Monza had also opened another investigation some time ago for alleged tax evasion concerning, in particular, unpaid VAT. Last December, in fact, on this front, the colossus reached a agreement with the Italian tax authorities, paying 511 million euro.
This first line of investigation, among other things, gave rise to another one in recent months, again in Milan, which hypothesises the crime of"smuggling for failure to declare" and which involves, in addition to the e-commerce group, about seventy alleged 'front men'. That is, the network of sellers of Chinese products allegedly handled by Amazon and on which, according to the prosecution, no VAT or tariffs were paid on importation. What's more, Amazon Italia Transport, one of the group's companies, after ending up in one of the many investigations by the Milan Public Prosecutor's Office on the so-called 'labour tanks' with a seizure of more than 121 million euros for tax fraud in July 2024, paid last December more than 180 million euros as compensation in tax cases. Today, with searches 'at third parties' of some managers not under investigation to acquire documentation and seize devices, a further and new evasion investigation has surfaced for an 'alleged hidden permanent establishment', i.e. income produced in Italy but without paying tax. Amazon had already paid around 100 million to the Italian tax authorities in December 2017 for similar allegations.

