A brand paying a UGC creator in Italy has three legal routes: occasional self-employment (prestazione occasionale), an invoice from a creator with a VAT number (partita IVA), or a copyright assignment for the content itself. Which one applies is not a preference — it follows from how often you use that creator and what you are actually buying. Get it wrong and the exposure sits with you, the payer, because in Italy the company withholding the tax is legally the sostituto d'imposta.
Almost every Italian-language guide on this topic is written for the creator. This one is written for the company signing the payment. This guide covers the three routes, the paperwork each one requires, the thresholds that quietly change your obligations mid-year, how to handle creators based outside Italy, and when running this yourself stops making sense.
This is not tax advice. The rules below are cited to their source so your accountant can check them against your specific case, which is exactly what you should do before the first payment.
Route 1: occasional self-employment
This is the default for a creator who makes you one or two videos and does not do this for a living. The creator issues a ricevuta per prestazione occasionale — a receipt, not an invoice, because there is no VAT number involved.
You withhold 20% and pay it to the tax office. Under art. 25 of DPR 600/1973, a company acting as sostituto d'imposta withholds 20% of the gross fee as ritenuta d'acconto. The creator receives 80%; you pay the remaining 20% to the Agenzia delle Entrate via form F24 by the 16th of the month following payment. The following year you issue the creator a Certificazione Unica recording what you paid and withheld.
The receipt needs a €2 stamp above €77.47. Any receipt over that amount carries a €2 marca da bollo. It is formally the creator's cost, but it is commonly recharged to the client — listed as a separate line after the withholding, since it is not compensation and is not part of the withholding base.
The €5,000 threshold changes the deal mid-year. Once a creator's total occasional-work income for the calendar year passes €5,000, INPS Gestione Separata contributions become due on the excess. The split is two thirds paid by the client and one third by the worker, and for 2026 the rate for those without other pension coverage is 33.72%. Two consequences for you: the creator's cumulative total across all their clients is what counts — you cannot see it, so ask — and the employer share is a real cost that lands on you, not on the fee you negotiated.
"Occasional" is a substance test, not a label. The route is only available for work that is genuinely non-habitual and not organised. Using the same creator every month, on a standing brief, is a professional relationship regardless of what the receipt says. That is the single most common mistake brands make when a pilot turns into a program.
Route 2: the creator with a VAT number
A creator who does this professionally issues an electronic invoice and the paperwork gets simpler for you. Since the ATECO 2025 classification, there is a code for exactly this activity — 73.11.03, influencer marketing — introduced with the new ATECO structure and operational from 1 April 2025.
The important variant is the regime forfettario, the Italian flat-rate small-business regime. You do not withhold anything from a forfettario creator — but you need their written statement on or with the invoice confirming they are in that regime. Keep it: it is your evidence for why no withholding was applied.
Route 3: paying for the content, not the shoot
If what you are buying is the right to exploit the video rather than the act of filming it, the payment can be structured as an assignment of the economic exploitation rights. The tax treatment is different and often better for the creator: under art. 54, paragraph 8 of the TUIR the taxable base is reduced by a flat 25%, or 40% if the creator is under 35. The 20% withholding applies to that reduced base, so the effective rate is 15% — or 12% for an under-35 creator. No invoice is required; the creator issues a receipt marked as outside the scope of VAT. Separately, art. 43 of L. 289/2002 excludes compensation for the assignment of copyright and image-rights exploitation from the contribution base up to 40% of the total received for the same activity.
The honest caveat: this route depends on the content actually qualifying as a protected work, and a fifteen-second product demo filmed to a brief is not obviously one. The characterisation has to match reality, not the tax outcome you would prefer. This is the route where an accountant's opinion in writing is worth the most — and where your rights and licensing terms and your tax treatment have to tell the same story.
Creators outside Italy
When the creator is established outside Italy and the service is relevant for Italian VAT, the VAT is settled by you through reverse charge — art. 7-ter of DPR 633/1972 — by issuing a self-invoice. Whether any Italian withholding applies to a non-resident creator depends on the applicable double-taxation treaty and on where the work is performed, so it is not a question to answer from a template. Budget the extra administrative step; it is routine, but it is not zero.
What this actually costs you, not the creator
Three lines that brands leave out of the budget. The withholding is inside the fee you agreed, not on top of it — a €500 gross fee means €400 in the creator's account. The employer share of INPS contributions above the €5,000 threshold is genuinely on top. And the administrative time — collecting receipts, checking regimes, filing F24s, issuing Certificazioni Uniche — scales with the number of creators, not the number of videos.
That last line is the one that decides the model. Paying three creators a year this way is trivial. Paying eighty is a finance function.
When doing this yourself is the wrong choice
When your program is built on many small creators. The per-creator overhead does not shrink with volume, and the €5,000 threshold has to be monitored per person. At that point the compliance load, not the creative budget, is what your team is actually managing — the same trade-off that decides in-house versus agency versus platform.
When you cannot answer "is this occasional?" honestly. If the truthful answer is that the collaboration is continuous, the fix is a VAT-registered creator or a platform that contracts them properly — not a stack of occasional receipts.
When the compensation is not cash. Free product, credits or cashback in exchange for content are still compensation, with both tax and disclosure consequences. The disclosure side is covered in incentivized reviews.
The practical rule: settle the route before the brief, not after the invoice. If your program is heading past a handful of creators, buying the contracting and payment layer is usually cheaper than building it — which is what a platform like TikJoy is for, paying creators directly for the content they publish.