Milan prosecutors have requested a criminal trial for Amazon’s European unit and four of its managers over alleged tax evasion worth about €1.2 billion, escalating a dispute that the US technology group had already settled with Italy’s tax authority.

Reuters reported on Thursday that prosecutors filed the request despite Amazon agreeing in December to pay €527 million, including interest, to Italy’s Revenue Agency to resolve the tax dispute. The payment would normally lead to the closure of related criminal investigations in Italy.

Two sources with direct knowledge of the matter told Reuters that Milan prosecutors chose not to follow the tax authority’s approach and instead pushed forward with the criminal probe. In previous cases involving other multinational companies, prosecutors typically dropped or settled investigations once tax liabilities had been paid.

A judge will now schedule a preliminary hearing to determine whether the case proceeds to trial or is dismissed. The request covers Luxembourg-based Amazon EU Sarl and four managers accused of involvement in the alleged scheme.

According to charges reviewed by Reuters, prosecutors allege that Amazon’s platform algorithms and operating model allowed tens of thousands of non-EU sellers, mostly from China, to sell goods in Italy without disclosing their identities. Authorities claim this structure helped those merchants avoid paying value-added tax on sales to Italian consumers between 2019 and 2021.

Italian law holds intermediaries jointly responsible for unpaid VAT by non-EU sellers using their marketplaces, prosecutors argue. In their request for trial, Milan prosecutors named Italy’s economy ministry as the injured party in the case.

Amazon has previously rejected the accusations. After the December settlement with the tax authority, the company said it would “forcefully defend its position on the potential ungrounded criminal case”.

The company also warned that “unpredictable regulatory environments, disproportionate penalties, and protracted legal proceedings are increasingly affecting Italy’s attractiveness as an investment destination”.

The case forms part of a broader series of investigations into Amazon’s operations in Italy. Reuters reported that the European Public Prosecutor’s Office is examining similar alleged offences covering the period from 2021 to 2024.

Milan prosecutors are also conducting separate probes into alleged customs and tax fraud linked to Chinese imports and whether Amazon maintained an undeclared permanent establishment in Italy between 2019 and 2024 that could have resulted in higher tax liabilities.

Italy’s privacy watchdog has also scrutinised the company’s practices. On 24 February it ordered a local Amazon unit to stop using the personal data of more than 1,800 warehouse workers near Rome.

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