the investigation
Amazon on trial in Milan: the cunning of the algorithm and the shadow of a 1.2 billion tax evasion (and pressures for favorable laws)
Milan investigation: techniques to evade VAT, data stored abroad, and suspicions of institutional relationships that could reshape the rules of e-commerce.
A tax dispute of 1.2 billion euros, an artificial intelligence system accused of "indifference" to regulations, and the shadow of improper institutional pressures. This is the picture outlined on March 12, 2026 by the Prosecutor's Office of Milan, with the request from prosecutor Elio Ramondini to bring Amazon EU S.à r.l. and four executives, three European and one American, to trial.
The focus is not only on the financial statements but also on the technological core and the entire commercial structure of the giant.
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According to the accusatory hypothesis, between 2019 and 2021, the architecture of the marketplace, governed by "predictive logistics algorithms" and "machine learning", would have systematically circumvented the application of 22% VAT on sales in Italy of products from non-EU sellers, largely Chinese.
What would make the company's position more serious is the alleged lack of transparency towards the Guardia di Finanza of Monza: in response to requests for traceability, Amazon would have provided "incomplete" and "inadequate" data, strategically stored on servers in Bangalore, India.
The multinational rejects the allegations, calling the proceedings "unfounded" and asserting its role as a major taxpayer, with 25 billion euros in investments in the country.
In December 2025, the company paid over 511 million euros to the Revenue Agency, which adds to a previous 212 million, for a total of 723 million, in order to close the administrative dispute.
However, criminal justice continues on an independent track: the dual regulatory regime prevents the payment from automatically nullifying any responsibilities for "fraudulent declaration", a charge linked to specific organizational choices and IT solutions.
The Milanese file is extensive and touches on further aspects. Suspicions of meetings with "institutional interlocutors" emerge, during the time of the Growth Decree, to "soften" the traceability obligations.
In February 2026, searches were carried out in relation to an alleged “stable hidden organization”, a circumstance that has already led the company to regularize 159 employees. Already in November 2025, a customs operation had suggested the smuggling of Chinese goods destined for Italian warehouses.
Now it is up to the preliminary hearing judge Tiziana Landoni to set the preliminary hearing. The repercussions of the proceedings could deeply impact the rules of global e-commerce: if the accusatory framework, supported by massive analyses from Sogei, holds up, platforms would be required to actively guarantee VAT. A potentially epoch-making turning point, capable of reducing price differentials fueled by evasion and rebalancing competition in favor of local operators against the overwhelming power of digital giants.