VIES Guarantee against VAT fraud and shell companies
The guide to mandatory surety bonds that protect foreign companies and guarantee legitimate business operations in Italy.
Italy has taken a major step to fight VAT fraud and protect companies that want to trade in its market legitimately. Several large fraud schemes have been uncovered in recent years. In Varese, one single VAT number was being used by over 1,300 e-commerce operators to avoid paying VAT. In Milan, a so-called fiscal representative managed 26,000 foreign operators with no offices, no employees, and no real business activity — just paper numbers hiding a huge tax fraud operation.
These cases are not rare exceptions. They reveal how shell companies can create unfair competition for legitimate businesses. For serious exporters and foreign suppliers, this is why the Italian government has introduced a mandatory VIES Guarantee for all non-EU companies that want to operate in Italy.
If you want to register for VIES in Italy and trade under the EU VAT regime, you must comply with these new rules. Request your VIES Guarantee today and make sure your company is fully compliant from day one.
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Understanding VAT and VIES Registration in Italy
VAT (Value Added Tax) applies to most goods and services sold in Europe. When your company buys or sells cross-border within the EU, you may use the intra-EU VAT regime. This regime uses the reverse charge mechanism, meaning the buyer accounts for VAT instead of the seller.
But this system has been abused by fraudsters for years. They sell goods or services, never pay VAT, and disappear — leaving the tax office, and honest competitors like you, with the damage.
This is why Italy now requires a financial guarantee for companies appointing a tax representative in Italy.
The Tax Representative Requirement
If you are a non-EU or non-EEA company selling goods or services in Italy, you must appoint a tax representative (also called fiscal representative). This person or entity:
- Registers you for VAT and VIES
- Manages your VAT returns
- Ensures you meet Italian tax obligations
But if the tax representative is unreliable or a shell company, your business risks being involved in fraud investigations and may lose the right to trade under the EU VAT regime.
What is the VIES Guarantee?
From April 14, 2025, every non-EU company that appoints a tax representative must present a VIES Guarantee. This is a formal guarantee in the form of:
- A surety bond (fideiussione) from an Italian bank or insurance company, or
- A cash deposit in Italian government bonds
This guarantee covers unpaid VAT debts if the foreign company does not meet its obligations.
Legal Requirements (Ministerial Decree – December 9, 2024)
The VIES Guarantee must meet these criteria:
- Minimum amount: €50,000
- Minimum duration: 36 months
- Beneficiary: The Director of the competent office of the Italian Revenue Agency
- Original paper document must be delivered to the agency (PEC/email not accepted)
Failure to provide the guarantee results in two reminders, after which the company is excluded from VIES and loses access to the intra-EU VAT regime.
Surety Bond vs. Cash Deposit
A surety bond is usually the preferred solution. It is issued by a bank or an authorized insurance company and does not require you to freeze capital. A cash deposit requires locking up €50,000 or more in government bonds for at least 36 months.
FAQs for Foreign Companies
Who must provide the guarantee?
All non-EU and non-EEA companies registering for VIES in Italy via a tax representative.
How long is it valid?
At least 36 months, renewable as needed.
Can I use any provider?
No. The surety bond must be issued by a bank or insurance company authorized in Italy and recognized by the Italian Revenue Agency.
What happens if I do not provide the guarantee?
Your company will be excluded from VIES and will no longer benefit from the intra-EU VAT regime.
How much does it cost?
The price depends on your company’s risk profile, but a surety bond is far cheaper than blocking capital in a deposit.
Real-World Examples
A Canadian company that appoints a tax representative and provides the €50,000 surety bond is approved for VIES registration and can trade without delays. A suspicious company with no office or employees that tries to open hundreds of VAT numbers cannot get a guarantee and is blocked from VIES registration.
Why Choose Italiafideiussioni.it
Working with the wrong provider can delay your registration or even get your application rejected. We work exclusively with banks and insurance companies licensed in Italy and supervised by the Bank of Italy and IVASS. Every VIES Guarantee we issue is fully compliant with the December 9, 2024 decree, including amount, duration, and beneficiary.
We deliver fast and transparent quotes within 24 hours. Our experts guide you step-by-step through the process, from drafting the correct wording to delivering the original document to the Italian Revenue Agency. This ensures that your VIES registration is successful the first time.
With us, you get more than just a policy. You get peace of mind, operational continuity, and the certainty that your company will be able to trade in Italy legally and safely.
Start Your VIES Registration Today
Protect your business, avoid costly mistakes, and enter the Italian market with confidence. Request your VIES Guarantee now and get a compliant, approved guarantee issued by authorized companies.
