The Revenue Agency in the response to ruling no. 325 clarified:
The VAT exemption is applicable to the sale of ships in favor of an SGR, which operates on behalf of an alternative mutual investment fund (so-called FIA), which, together with the transfer of ownership, grants the same in leasing to third parties (in this case, the transferring companies), for the exercise of commercial activity on the high seas of passenger transport.
To demonstrate that the ship is used for navigation on the high seas, only one declaration can be submitted by the FIA (through the SGR), whose receipt protocol will be reported in the ship transfer invoice and used in the reports. with suppliers / subcontractors.
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