With its answer to question no. 740/2021, the Inland Revenue has provided clarifications on the dematerialisation of expenses claims produced by employees on business trips.
The requesting company wanted to completely dematerialise expenses claims produced by its employees on secondment, which allows their “creation, control, accounting and storage in a fully digitalised format.”
The creation of an expenses claim and the compilation and sending of a report containing the reasons for the trip is the employee’s responsibility, who can either carry out the process independently or have a delegate do it on their behalf. Each employee is provided with a unique user account to access the corporate portal and the relevant services. Each of these user accounts is unique and associated with a password to be changed monthly. The administrative office then carries out the necessary checks, verifies compliance with tax rules for deductibility and approves the expenses claim, receipts and invoices relating to the business trip. The accounting procedure is automatic, and the documents are stored electronically.
Requesting company’s interpretation
The company considers that the procedure complies with the regulatory reference, allowing the travellers’ electronic management of expenses claims and their dematerialisation and electronic storage, together with the relevant receipts.
In the question, the company noted that the procedure ensures the unequivocal traceability of the employee to the expenses claims through secure and monitorable access. Since the expenses claim is an electronic document or unequivocally traceable to the employee, it does not require a paper document that is subsequently signed, or an electronic or digital signature (however, this will be affixed, together with the time stamp, by those in charge of storage later). This system would limit paper storage only to expenses incurred with suppliers residing in non-EU countries with which Italy does not provide mutual assistance in tax matters.
The Inland Revenue, recognised the procedure’s validity and said it was consistent with practice in which “any IT document with tax relevance – i.e. any electronic document containing the IT representation of acts, facts or data legally relevant for tax purposes […] – such as expenses claims which will be used for the deductibility of the relevant costs under Presidential Decree no. 917 of 22 December 1986 no. (TUIR), must be non-modifiable, complete and authentic.”
The tax authority stated that “where such features are present […] there is nothing to prevent paper documents from being replaced electronically and the procedure from being entirely dematerialised.”
Based on the information provided by the requesting company, the Inland Revenue defines the procedure as similar to those described in answers no. 403 and no. 417 of 2019. Therefore, in its opinion, nothing prevents the adoption of the process requested by the company if the dematerialised documents are non-modifiable, complete and authentic (a condition which cannot be verified as part of the answer).
According to the Inland Revenue, “the expenses claim is generated directly by the traveller by accessing the corporate network, and produced by a delegate, who acts on behalf of the delegating party, […] which can be tracked by the system. Expenditure evidence, even if dematerialised, must meet the requirements (such as relevance, relevant dates and congruity) that allow the deductibility of costs and the attribution of income to employees who are reimbursed for the expenditure.”