Per la Corte di Giustizia è detraibile l’Iva pagata all’acquisto, relativamente al locale usato per l’attività professionale

Con la sentenza del 21 aprile 2005 relativa alla causa C-25, la Corte di Giustizia europea ha stabilito che un professionista può legittimamente dedurre l’Iva versata per la costruzione dell’immobile costruito insieme al coniuge, limitatamente alla porzione che egli utilizza per l’esercizio della sua attività professionale.

La causa riguarda un professionista tedesco che adibiva a studio professionale un locale della sua abitazione.

I giudici hanno fatto riferimento alla direttiva 77/388/ CE in materia di armonizzazione delle legislazioni degli Stati membri sull’imposta sul valore aggiunto, spiegando che qualora una persona acquisti o faccia costruire una casa per viverci con la famiglia, agisce in qualità di soggetto tassabile, e ha quindi il diritto alle deduzioni ai sensi l’articolo 17 della suddetta direttiva, anche nel caso in cui destini ad ufficio un locale dell’immobile, anche se accessorio, e ascriva tale parte dell’edificio al patrimonio della sua impresa.

Nel caso in cui due coniugi, senza personalità giuridica e che non esercitano un’attività economica, affidino a terzi la realizzazione di un bene di investimento, i suddetti coniugi (comproprietari) sono da considerarsi i destinatari della transazione ai fini della direttiva.

Inoltre – si legge nella sentenza – se una coppia acquista un bene di investimento, parte del quale è usato esclusivamente per gli scopi lavorativi da parte di uno dei due comproprietari, quest’ultimo può dedurre l’IVA relativa alla costruzione, limitatamente alla quota dell’immobile che usa per la sua attività lavorativa.

Infine, gli articoli 18 comma 1 a) e 22 comma 3 della sesta direttiva non richiedono che il soggetto passivo dell’imposta, per potere esercitare il diritto alla detrazione, conservi una fattura intestata a sè o dimostri che le percentuali dei pagamenti e dell’Iva corrispondano alla propria quota del bene in comproprietà. È sufficiente una fattura intestata ad entrambi i coniugi comproprietari.

In Italia, invece, la destinazione d’uso residenziale o professionale di un immobile è definita dalla classificazione catastale, a prescindere dall’uso effettivo dei locali. Hanno destinazione residenziale quelli appartenenti alle categorie da A/1 ad A/11, ad esclusione della A/10 (uffici e studi privati).

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