“Navigating the high seas” VAT exemption – only for vessels involved in a commercial activity

The Italian Revenue Agency (Agenzia delle Entrate), in its reply no. 175 of January 31, 2023 has confirmed that in order to benefit of the non-taxable VAT status provided for by Article 8-bis, (1) (a) of the VAT decree (Presidential Decree No. 633/72), it is not sufficient that the vessel is used for navigation on the high seas but the vessel must also carry out a commercial activity. Therefore, in its answer no. 175/2023, the Revenue Agency denied the possibility of applying for this exemption if a vessel is used for navigation on the high seas but carries out activities of scientific research.