Extra-EU supplies: Transfer of ownership is a necessary condition for VAT non-taxability
MARCH 21, 2025
The Revenue Agency’s answer No. 34 of February 14th 2025 marks a change of course from the previous answer No. 238 of August 3rd 2020. The topic being addressed is the VAT treatment of supplies of goods that have already been exported.
According to the Agenzia delle Entrate, when the transfer of ownership of the goods takes place in non-EU territory, the transaction does not meet the territorial requirements of Article 7-bis of Presidential Decree No. 633/1972, thus falling outside the scope of VAT and precluding the possibility of benefiting from the non-taxable regime provided for by Article 8.
The purpose of a post-export sale is no longer sufficient to apply non-taxable VAT. Traders, in order to benefit from non-taxability, must now comply with specific exceptions, such as in the case of call-off stock agreements or already identified purchasers, abandoning the previous approach that allowed non-taxability even in the case of post-export sales.
Mr. Fabio Pasquale
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