Summary of the Decision (Italian Tax Court of Appeal – Liguria, Judgment No. 200/2026) The Italian Tax Court of Second Instance (Liguria) upheld the taxpayer’s appeal against a first-instance decision concerning import VAT (€583,000 plus interest) assessed by the Italian Customs Authority. Background The case involved the owner of a yacht accused of breaching the […]
Author Archives: Domenico Rinaldi
04
Feb
Feb
A practical reading of Italian Revenue Agency Ruling No. 10/2026 (Article 5(5), Law 88/2001) Reference: Italian Revenue Agency (Agenzia delle Entrate) – Ruling (Risposta a interpello) No. 10/2026 – Subject: “Taxation of income earned by seafarers boarding foreign-flag vessels – Article 5(5) of Law 16 March 2001, No. 88”. A foreign flag does not automatically […]
12
Nov
Nov
For charters of pleasure yachts, the exemption from excise duty on fuel does not apply, since the vessel’s use by the charterer or lessee is recreational, not commercial. Italian Customs Agency clarification In Circular No. 26/2025, the Italian Customs Agency clarified that: The exemption from excise duty on fuel, pursuant to the Ministry of Economy and Finance Decree No. 225 of […]
25
Jun
Jun
Introduction and Regulatory Background In the yacht-leasing sector, Italian VAT law lays down a special regime for pleasure yacht used outside the European Union. Under Article 7-sexies(1)(e-bis) of Presidential Decree No 633/1972 (introduced by Law No 160/2019), only the portion of the leasing service corresponding to use within the EU is territorially relevant and therefore […]
18
Jun
Jun
With Resolution No. 39/E dated 6 June 2025, the Italian Revenue Agency has introduced tax code 2510, to be used by insurance companies when paying stamp duty on communications related to life insurance contracts, calculated for each year up to and including 2024. The first payment deadline is set for 30 June 2025. This new […]
18
Jun
Jun
Con la Risoluzione n. 39/E del 6 giugno 2025, l’Agenzia delle Entrate ha istituito il codice tributo 2510, che dovrà essere utilizzato dalle compagnie assicurative per il versamento dell’imposta di bollo sulle comunicazioni relative ai contratti di assicurazione sulla vita, calcolata per ciascun anno fino al 2024, la cui prima scadenza è il 30 giugno […]
Updates
Italian Customs Agency Circular 8/2025: Temporary admission, maintenance works and spare parts
28
Apr
Apr
On 10 April 2025 the Italian Customs Agency has issued Circular No. 8/2025 to clarify procedures for non-EU yachts entering Italian waters, in light of recent legislative changes (Legislative Decree 141/2024). Temporary admission The previous guidelines provided in Circular No. 20/2022 have been confirmed, according to which “Temporary admission” regime allows non-EU private pleasure craft […]
Updates
Major change in the rules regulating the activities of Tax Representatives of Yachts carrying out charters in Italy
24
Apr
Apr
Italy has introduced significant changes to the rules governing tax representatives for VAT purposes for non-resident entities. We remind you that companies not resident in the EU are required to appoint a tax representative in Italy in the case of charters departing from Italy, in order to comply with all Italian VAT obligations. In fact, […]
16
Jan
Jan
In response to the question raised by an Italian company (“Alfa Srl”), specializing in the rental and leasing of passenger vessels, the Italian Revenue Agency (“Agenzia delle Entrate”) has issued a crucial resolution (Risposta n. 1/2025) that allows to apply for VAT exemption on a yacht undergoing a “major refit”. The resolution revolves around the […]
16
Jan
Jan
Flavio Briatore, after having been definitively acquitted of charges of tax fraud concerning his yacht “Force Blue,” has commenced legal proceedings before the Court of Turin to claim damages against both the court appointed administrator and certain judicial authorities involved in the case. Specifically, Mr Briatore is claiming EUR 12.66 million to compensate damages for […]