Amazon, the US e-commerce giant, has reached a significant agreement with the Italian Revenue Agency, committing to pay a total amount of 723 million euros. The agreement closes a complex tax affair arising from investigations coordinated by the Public Prosecutor’s Office of Milan and conducted by the Guardia di Finanza (GdF) and the Revenue Agency.
The 723 million euros represent the sum of two separate assessment actions. To an initial payment of 212 million euros, already defined in recent days by two companies of the group in Italy, 511 million euros have now been added, agreed directly with the Luxembourg holding company. The Group will be able to take advantage of installment mechanisms for payment.
The agreement with the Luxembourg Holding
The majority of the agreement, the 511 million euros, concerns the holding company Amazon Sarl, based in Luxembourg. The investigations of the Guardia di Finanza focused on the activities carried out through the company’s platform with particular attention to findings for the purposes of Value Added Tax (VAT).
The crux of the matter concerns transactions made by millions of “third parties” – sellers who use Amazon’s platform. According to European legislation, digital platform operators have specific reporting obligations to allow national whistleblowers to collect the tax. Amazon, although not the direct actor of all the sales, was called upon to respond jointly and severally for the unpaid taxes relating to these operations.
The investigations into Amazon Italia Logistics and Transport
The other 212 million euros are the result of two investigations conducted by the anti-fraud units of the Revenue Agency against two Italian entities of the group: Amazon Logistica and Amazon Italia Transport.
In this case, the tax relief is linked to a case technically defined as “digital hetero-direction of workers”. This concept refers to the use of Italian staff in a way that, in effect, framed them as if they were operating abroad, raising questions about correct taxation and contributions in Italy.
The role of the Milan Public Prosecutor’s Office
It is essential to underline that the entire assessment and definition process was coordinated by the Public Prosecutor’s Office of Milan, which led the joint work of the Guardia di Finanza and the Revenue Agency, bringing to light the complex tax architectures of the electronic commerce giant. Today’s agreement represents a significant step in the fight against tax evasion and avoidance by large multinational groups operating in Italy.