2023 Budget Law: new measures for open and closed VAT numbers

Today’s theme will be that of VAT numbers called “open and close”. What will be their risks of use and what measures are foreseen?

With regard to the so-called “open and close” VAT numbers, a new measure has been inserted in the new one Budget law 2023. The goal is to prevent VAT numbers from being opened and closed in short periods, with the aim of evading the tax authorities. That way it would come evaded the payment of direct and indirect taxes.

To remedy this problem, an entire chapter has been dedicated to the situation within the new Budget Law. The plan calls for tight controls, possible office closures, and large fines. Let’s see together what the risks may be resulting from this particular practice.

VAT number open and close: what is it and what does the 2023 Budget Law provide?

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The practice of opening and closing a VAT number in short periods, which thus avoids coming found by the tax authorities and having to pay taxesis what is defined as “VAT number open and close”.

This is a more common practice by non-EU entities, which can more easily become untraceable. All before the financial administration is able to intervene. Among the new measures envisaged by the 2023 Budget Law, there is also a plan to counter open and close VAT numbers.

The plan includes:

  • blanket checks by the financial administration on the various communications of the opening of new businesses (and therefore VAT numbers), with possible cross-examination in the office, in the case of activities deemed more at risk;
  • the possible closure of the office, for those entities unable to pass the required checks;
  • administrative fine of 3,000 euros to be paid by the tax payer.

It will be mainly the ones who have to carry out the checks the Revenue Agency. In practice, following a risk analysis, the taxpayer may be required to present himself at the AdE offices, with a series of documents, to demonstrate the effective exercise of the activity.

What are the positions at risk of controls starting from 2023?

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The categories that will be monitored are:

  • self-employed;
  • individual entrepreneurs;
  • and legal representatives of companies, associations or entities with or without legal personality

The surety of 50 thousand euros


If the controls of the Revenue Agency are not passed, the opening of the new VAT number can only take place at followed by a bank or insurance guarantee for a minimum of three years and not less than 50,000 euros. This guarantees another person’s obligation. In this case, since the taxman does not consider the taxpayer reliable (that is, it is feared that he will close the VAT number before paying the due contributions, and then disappear), an additional step is required. In the event that there are tax offenses or tax violations, the surety will act as a guarantee.

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2023 Budget Law: new measures for open and closed VAT numbers

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