The Revenue Agency clarified that the transfer of the import license constitutes a provision of services subject to VAT, pursuant to art. 3 paragraph 2 no. 2) of Presidential Decree 633/72. The case presents similarities with the intangible rights object of previous clarifications of practice ( see resolutions nos. 51/2006 , 20/2011 and 71/2009 as well as circular no. 32/2009 ), which comply with the position expressed by the EU Court of Justice. In particular, the judgment of 8 December 2016 in case C-453/15 states that the emission quotas and the rights to issue them “are immaterial , confer on their owner an exclusive right and can be transferred to third parties, depending on the case, as a result of assignment or concession, aimed at allowing third parties to use them for the purposes of an economic activity”
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