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Storage deposits with third parties - TRADERS

The 2018 budget law introduced a series of provisions aimed at preventing and combating tax evasion and fraudulent phenomena regarding the payment of VAT in the field of extracting energy products from deposits (Article 1, paragraphs 945 to 959, law 205/2017). In particular, Article 1, paragraphs 945 to 959, of Law no. 205/2017, provided that those who intend to store energy products at third party warehouses must be identified and monitored by the Customs and Monopolies Agency. These subjects, hereinafter referred to as "Traders", are commercial operators in the oil sector who, not having their own storage facilities at their disposal or having them in places other than those where the products are hesitated, make use of plants owned by third parties belonging to authorized custodians or registered recipients.

With the decree of 12 April 2018, the Minister of Economy and Finance established the methods by which the aforementioned Traders must be identified by the Customs and Monopolies Agency and the methods of transmission of the information flow of accounting data between the Administrations concerned.

In particular, in the aforementioned decree it was established that:

  • Traders, before starting the storage activity at third party deposits, must obtain an authorization from the competent Customs Office upon presentation of a specific application. This authorization is valid for two years and must be associated with a unique identification code;
  • for Traders in Italy who already hold a tax warehouse for energy products, the application is replaced by a communication to be transmitted exclusively digitally at least thirty days before the start of the storage activity. This communication is valid for one year and must be associated with a unique identification code;
  • in order to proceed with the storage of the products, the Trader must obtain a specific agreement from the authorized warehousekeeper or registered recipient where he/she intends to store the products. The agreement perfects the relationship between the two parties and the storage activity can be carried out;
  • Traders must draw up a summary of the daily quantities of energy products stored at each third party warehouse.



Online assistance for the applications Digital Traders and Deed of Assent