The objection Italian brands raise most often, taken seriously: the two payment flows, who withholds what, and the difference that shows up in your accounts at year end.
The line you hear is "Italian creators without a VAT number cannot be paid on commission, you have to withhold tax". It is wrong in the way it is phrased and right on a point almost nobody mentions. In native affiliate the brand never pays the creator: TikTok deducts the commission from the seller's settlement and credits the creator, so the brand is not the party paying the fee and applies no withholding. The 20 percent withholding belongs to a different scenario, the off-platform deal paid directly by the brand. The part that matters landed in late July 2026: TikTok now issues the tax documents on the creator's behalf, and they are an invoice if the creator is VAT registered and a plain receipt if not. The receipt is not deductible for the seller. So the right question is not "can I pay them", it is "what does that commission really cost me".
It comes up in almost every first call with an Italian brand. You get to the commission model, the e-commerce lead nods along, and then the objection arrives: Italian creators do not have a VAT number, so you cannot pay them a commission, you have to treat them as occasional contractors and withhold tax. Said that way the conversation ends, and the brand goes back to buying flat-fee posts.
It is worth taking apart slowly, because there is an error inside it and also a piece of truth that few people know. This page describes how payments work in the TikTok Shop affiliate programme and what documentation comes out of them. It is not tax advice: every creator and every company sits on its own set of facts, so the last word belongs to an accountant, not to this page.
In the form we hear it: the creator is an individual with no VAT number, so any fee they receive is occasional self-employment income; on that fee the client has to apply the 20 percent ritenuta d'acconto and act as withholding agent; and since a variable commission cannot be predicted in advance, the mechanism becomes unmanageable and is not worth the trouble.
Every single step of that reasoning is correct. The problem is that it describes a different scenario from native affiliate: it assumes the brand is the one paying the creator. In TikTok Shop affiliate, that is not what happens.
When a creator promotes a product and a sale follows, the money can travel two completely different routes with different tax consequences. Confusing them is where the whole objection comes from.
Native affiliate. The seller sets a commission rate in Seller Center. The creator joins the programme, promotes, and when the order completes TikTok calculates the commission on sales net of refunds, deducts it from the seller's settlement and credits it to the creator's balance, which the creator later withdraws. The brand issues no transfer to the creator and never sees their bank details.
Off-platform deal. Brand and creator agree a fee, fixed or variable, settled outside TikTok. Here the brand pays directly, and everything the objection describes applies: if the creator has no VAT number and the work is occasional, the brand is the withholding agent and applies 20 percent on each payment.
| Native affiliate | Off-platform deal | |
|---|---|---|
| Who sets the fee | the seller, in Seller Center | brand and creator, by negotiation |
| Who actually pays the creator | TikTok, into the creator balance | the brand, by transfer |
| Where the money comes from | deducted from the seller's settlement | the brand's bank account |
| Brand is the withholding agent | no, it does not pay the fee | yes, where the work is occasional |
| 20% ritenuta d'acconto | not applied by the platform | yes, on every payment |
| Document the brand receives | invoice or receipt issued on the creator's behalf | invoice, or occasional-work receipt |
There is a structural reason behind the middle row. For people resident in the European Economic Area the TikTok contract is with TikTok Technology Limited, a company incorporated in Ireland. Italian withholding is an obligation of Italian withholding agents, a category a foreign company with no permanent establishment in Italy does not belong to. That is why no Italian deduction shows up on the creator's balance.
The short version to say on a call. In native affiliate you are not paying an individual, you are conceding a percentage the platform deducts from your own settlement. A creator without a VAT number can take part. What changes is the document that comes back to you, and that part does concern you.
This is the new part, and the reason the objection deserves a real answer rather than a flat "you are wrong".
Since late July 2026 TikTok Shop has run automatic issuing of tax documents for affiliate commissions through the regulated tax service provider Fonoa. The creator authorises the service once from their creator profile, and from then on documents are generated and sent to the seller on their behalf. TikTok Seller University documents the service for France, Germany, Spain and Ireland, and it also runs in Italy, where generation is weekly, every Wednesday, at no cost to the creator.
The distinction that matters to the brand's accounts is between the two document types:
Put plainly: a 15 percent commission conceded to a VAT registered creator is a documented deductible cost; the same 15 percent conceded to a creator without a VAT number is an outflow that lands differently at year end. It is not a prohibition, it is a higher effective cost at the same headline rate.
And that, not the withholding tax, is why the composition of the roster is worth looking at before launching an affiliate programme. The client's objection reached a sound conclusion, "creators without a VAT number cost me something extra", from the wrong premise.
On the other side of the table the confusion is just as common, and in practice it is the real brake: plenty of creators refuse commission out of tax anxiety, and brands conclude the model does not work.
The test that triggers the VAT number obligation is not the amount, it is habituality. A creator promoting products continuously and in an organised way to produce income is carrying on a habitual activity, and at that point needs a partita IVA regardless of what they have earned. Someone doing it genuinely sporadically stays inside the occasional-work perimeter.
This is the most widespread misunderstanding of the lot. The 5,000 euro of annual occasional fees is not the threshold above which you open a VAT number. It is the threshold above which registration with the INPS Gestione separata kicks in, with contributions due on the excess only, split two thirds to the client and one third to the worker. It is calculated on the annual total of all occasional fees across every client. The VAT number, again, follows from habituality.
Since 1 January 2025 there is a dedicated code: ATECO 73.11.03, influencer marketing activity, introduced precisely to separate people working on social media professionally from people doing it as a hobby, and operational on the INPS side from 1 April 2025. Under the flat-rate regime the associated profitability coefficient is 78 percent, with the 2026 revenue and fee ceiling confirmed at 85,000 euro a year and a substitute tax of 15 percent, reduced to 5 percent for the first five years where the conditions are met.
Worth saying out loud to hesitant creators, because the unspoken alternative is often "nobody will see it". They will. The DAC7 directive, implemented in Italy by Legislative Decree 32/2023, requires digital platforms to report to the Agenzia delle Entrate each year the amounts paid to sellers and creators resident in Italy. Reporting is triggered above 30 transactions a year or 2,000 euro per platform, and declaration obligations still apply below those thresholds.
Three mistakes we see repeatedly, all of them born from trying to route around the problem instead of reading it.
Rule of thumb. Commission is always conceded natively from Seller Center. Any fee that leaves the brand's own bank account is a separate contract with its own rules.
The way we set it up in pilots, when the roster is mixed, is two separate tracks that never touch.
If you are weighing the commission structure more broadly, the full map of the rates TikTok applies to sellers across European markets is in the guide to TikTok Shop commissions.
Not to join the affiliate programme and promote products. An Italian creator needs a partita IVA when the activity becomes habitual, meaning continuous and organised to produce income, and that test depends on continuity rather than on amounts. The 5,000 euro a year figure almost everyone quotes is about something else: it triggers registration with the INPS Gestione separata and contributions on the excess, not the obligation to open a VAT number.
Yes. In native affiliate the brand never pays the creator directly: TikTok deducts the commission from the seller's settlement and credits it to the creator's balance, which the creator then withdraws. The creator still has to declare that income, and since July 2026 the platform issues them a commission receipt rather than an invoice.
The 20 percent ritenuta d'acconto is the mechanism for occasional self-employment fees paid by an Italian withholding agent, so it belongs to off-platform deals where the brand pays the creator directly. In native affiliate the brand does not make the payment and the platform applies no Italian withholding. How that interacts with an individual creator's tax position is a question for an accountant rather than a rule to infer from this page.
Since late July 2026 TikTok Shop, through the tax service provider Fonoa, issues tax documents on the creator's behalf to the seller: a compliant electronic invoice if the creator is VAT registered, and a commission receipt if they are not. The receipt documents the payment but cannot be used directly by the seller to deduct. In Italy the documents are generated weekly, every Wednesday, and the service is free for the creator.
TikTok Seller University documents the affiliate commission invoicing service for France, Germany, Spain and Ireland, and it also runs in Italy, where documents are generated every Wednesday. The creator authorises the service once from their creator profile, and invoicing starts from the first full month after authorisation and VAT details are complete.
Yes. The DAC7 directive, implemented in Italy by Legislative Decree 32/2023, requires digital platforms to report annually to the Agenzia delle Entrate the amounts paid to sellers and creators resident in Italy. Reporting is triggered above 30 transactions a year or 2,000 euro of consideration per platform, and the creator's own declaration obligations apply below those thresholds too.
Sources: TikTok Seller University, Affiliate Commission Tax Invoices & Receipts, TikTok Seller University Italy, platform commission, TikTok Terms of Service for the European Economic Area, Confcommercio, new ATECO code 73.11.03, influencer marketing ATECO code, LegaleFiscale, TikTok Shop Italy 2026 tax guide, the 5,000 euro threshold and Gestione separata, DAC7 and platform reporting obligations. Platform rules and tax thresholds change often, so check the source before making a binding decision. All sources re-checked by Enclaverse on 31 August 2026. This page describes how the platform works and the general framework, and is not tax advice.
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