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Ruling 370: Transport relating to goods in transit – Non-taxable

In terms of the VAT exemption regime for transport services, in addition to the correct identification of the goods being transported as “goods in transit”, for the purposes of the non-taxability of it is necessary that there is an additional requirement, that is, that the company is ” holder of the transit procedure “. The exemption only applies to “direct” services.

If it were recognized that the goods purchased and sold by the company are ” goods in transit “, the Inland Revenue specified that the aforementioned VAT exemption regime would apply on condition that the company is the holder of the transit procedure. Thus, in fact, the new art. 9 last paragraph of Presidential Decree 633/72 introduced by art. 5- septies of Legislative Decree 146/2021 (conv. L. 215/2021 ), starting from 1 January 2022

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