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Simplified accounting: tax authority alert regarding declared revenue and costs

The Italian Revenue Agency is sending out questionnaires to clarify discrepancies between declared revenue and bank transactions, and between costs and electronic invoices, with the risk of penalties and tax assessments

Contabilità e pianificazione di bilancio. (Adobe Stock)

2' min read

Translated by AI
Versione italiana

2' min read

Translated by AI
Versione italiana

The Italian Revenue Agency is currently sending out questionnaires to taxpayers engaged in business activities, pursuant to Article 51 of Presidential Decree 633/72 and Article 32 of Presidential Decree 600/73, requesting explanations regarding two possible discrepancies: a declared turnover that is lower than bank receipts, and costs stated in the tax return that exceed the electronic invoices recorded by the SdI.

The aim is clear: to uncover any undeclared income and identify fictitious expenses that have unduly reduced the taxable amount.

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The deadline for replying is fifteen days, and the consequences of failing to reply could be particularly serious. In addition to an administrative fine of between 250 and 2,000 euros, you risk having your income assessed on an inferential basis.

The questionnaire is primarily aimed at taxpayers who operate under the simplified accounting scheme, for whom the cash basis of accounting applies (Article 18 of Presidential Decree 600/73).

The Revenue Agency’s request raises concerns on at least two counts: one relating to bank income figures and the other concerning costs.

With regard to the first of the two points mentioned, it should be noted that the tax authorities compare the year’s turnover with bank receipts, overlooking the fact that, from a financial perspective, not only turnover but also VAT on invoices issued is credited to the current account. In other words, for an invoice of 100, plus VAT of 22, and a bank deposit of 122, the tax authorities compare 100 in revenue against financial receipts of 122, highlighting an anomaly that does not, in fact, exist.

Furthermore, as only all incoming transactions in current accounts are counted, in the case of a business with multiple bank accounts – perhaps even with different banks – even simple bank transfers are recorded as receipts.

Consider the following example: the taxpayer holds three current accounts in the company’s name and receives an invoice payment of 100 into account A. They then transfer 100 from Account A to Account B and, subsequently, transfer a further 100 from Account B to Account C. In the tax questionnaire in question, bank receipts total 300 against a single invoice collected for 100, again highlighting a discrepancy that does not actually exist.

As regards costs, however, the matter is more straightforward: in 2021, there was no obligation for flat-rate taxpayers to issue electronic invoices and, therefore, in all likelihood, any costs not recorded in the SdI will be found amongst the paper invoices issued by such taxpayers, amongst occasional self-employed services, and amongst any further residual expenses arising from non-electronic costs (for example, rent paid to private individuals, insurance).

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