Once again, we return to the subject of the taxation of crew members on board vessels, given that the relevant regulations have recently been amended by Article 2-bis of Decree-Law No. 38 of 2026, as converted into Act No. 88 of 2026, which introduced into Article 3, paragraph 3, of the Italian corporate income tax code a new provision for exclusion from the personal income tax base.
It is clearly evident to everyone that, in recent years, Italy has become one of the most attractive countries for foreign individuals – whether from within or outside the EU – who decide to move to our country. The reasons for this may vary, often linked to the application of one of the many favourable tax regimes, or simply to the choice to live in one of Italy’s many beautiful, traditional locations – and, we might say, perhaps even unique in the world.
With the recent Circular No. 11/2026, the Custom Agency has once again addressed the temporary admission regime, providing very useful clarifications for operators in the sector, with particular reference to the phases of restriction and clearance of the regime, as well as to the user of the yacht, in the two different scenarios of private or commercial use.
In a judgment delivered on 4 March, the Liguria Regional Tax Court of Appeal upheld the defence argument put forward by a non-EU company regarding the criteria for interrupting the temporary admission period.
With summer approaching and the yachting season in full swing, discussions on issues affecting the yachting world are once again highly topical, and among these, the taxation regime for crew members is always a hot topic.
The 2026 Budget Law amended the VAT regime applicable to trade-ins of goods and services. In particular, in order to overcome a finding of incompatibility between national legislation and Article 80 of the VAT Directive, it was necessary to amend the provision of Article 13 of the VAT Code under Presidential Decree No. 633/1972 which, for the purposes of invoicing a good or service given in exchange, took as the taxable base to which the VAT was to be applied the normal value of the goods or services in exchange.