The Insight

IRS questionnaires to influencers: how the new control season works

Revenue Agency asks for contracts, account statements and activity data: 15 days to reply, penalties in case of omission

3' min read

Translated by AI
Versione italiana

3' min read

Translated by AI
Versione italiana

The world of influencers and content creators has officially entered the radar of the tax authorities. Over the last few weeks, the Inland Revenue has sent detailed questionnaires to numerous operators in the sector - not only prominent figures on social networks but also communication agencies and entities that intermediate commercial collaborations - aimed at reconstructing the real economic dimension of their activities.

This is an instrument that, at least at this stage, has a collaborative and not yet an ascertaining approach. Recipients have fifteen days to respond, providing all requested documentation on their activities in the years 2020 and in some cases also 2021 and 2022. It is important to clarify that although this is an informative questionnaire, omission is not without consequences. If one chooses not to answer, the immediate risk is the application of administrative sanctions of between €250 and €2,000, in addition to the inductive determination of income. In more serious cases, if false or misleading information is provided, criminal repercussions are not excluded.

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The content of the questionnaires is broad and touches on different aspects of digital activity. The administration asks for the social networks used, the nicknames and email addresses linked, the URLs of the channels, the type of content produced and the fees received. This information is supplemented by requests for contractual documentation with brands and agencies, invoices issued, including those to foreign counterparties, and bank statements showing the relevant financial flows.

The aim is to get as detailed a picture as possible of the activity carried out by infuencers, with a focus on the different methods of monetisation (advertising campaigns, presence at events etc.) and the methods of collection (digital wallets, currents etc.).

In addition to this, there is no shortage of questions about relationships with other content creators, shareholdings in companies and remuneration received in the form of goods or services, a widespread practice in the industry.

The operation is part of a broader path of 'normalisation' of the so-called creator economy. As of 1 January 2025, the Ateco code 73.11.03, dedicated to influencer marketing activities, was in fact introduced. This is an important step that will allow, in the coming years, a more precise monitoring of the phenomenon also from a statistical and economic point of view.

However, the control game is not only played on the tax front. In fact, with Circular No. 44 of 19 February 2025, the INPS clarified that, in certain circumstances, influencers no longer fall under the sole INPS Separate Social Security Contribution or the Merchants and Artisans Management, but also under that relating to actors or entertainment workers. When the activity takes on an artistic or interpretative character - think of the creation of promotional content in which the creator acts, poses as a model or assumes a role similar to that of the show business - the obligation to contribute to the Fondo Pensioni Lavoratori dello Spettacolo (FPLS), the former Enpals, is triggered. This is a step that significantly affects social security management, as it introduces a double track: on the one hand, purely commercial promotion activities, and on the other, services attributable to the world of entertainment.

The sending of the questionnaires therefore represents a first concrete step towards stricter and more structured regulation of a sector that until a few years ago lived in a kind of grey area. For operators, a delicate phase is opening up, in which compliance can no longer be postponed. Bringing order to the documentation, clearly distinguishing the different types of activities and verifying the consistency of the tax and social security framework is now becoming indispensable.

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