18 July 2017



UCINA Confindustria Nautica welcomes the position taken by Federagenti with Assorimorchiatori and Fedarlinea, which after a few months align themselves with the request for clarification on Altomare navigation presented to the Revenue Agency by UCINA itself together with Anpan at the beginning of last May .

“It’s a pity that even then there wasn’t the strength and will to cohere, given that – as today’s note demonstrates – there were no substantial differences in content”, comments the President of UCINA Confindustria Nautica, Carla Demaria. “A quicker response to the interests of the associates would have helped to obtain a very important and vital result for many companies sooner. However, we trust that the addition of these important signatures, now on the eve of the issuing of the Agency’s clarifying circular, is a good starting point for continuing together in the future”.

The position expressed by Federagenti with Assorimorchiatori and Federlinea summarizes the most relevant elements of the detailed document which last May was the result of joint work between the technicians of various Associations, but which was then finalized only by UCINA and Anpan, which had opened the confrontation with the Revenue Agency. The answer, after the technical comparison and some meetings with the Agency’s offices, is expected very soon.

The contents of the requests made in May by UCINA Confindustria Nautica:


Soon pronouncement of the Revenue Agency


The Revenue Agency is about to provide clarifications regarding the definition of navigation on the “high seas”, with the issue of a supplementary resolution to n. 2/E of 2017. The offices have been working for two months on the proposals presented by UCINA Confindustria Nautica and ANPAN (Association of Naval Superintendents and Contractors). After a series of meetings with the heads of the financial administration, a new resolution is expected within a few weeks.

The legislation on navigation on the “high seas” is fundamental for the competitiveness of the entire Italian maritime cluster. In fact, the legislation determines the methods of application of article 8-bis of Presidential Decree 633/72, which establishes the regime of non-taxability of VAT to operations referring to “vessels used for navigation on the high seas” for transport, line, fishing, salvage and assistance, commercial pleasure boating. And since the term “operations” refers as much to purchases as to supplies and supplies, it is clear that the vitality of our maritime economy passes through here.

The Vice President of UCINA in charge of tax dossiers, Maurizio Balducci, explains: “We have worked towards adopting European criteria, trying to have as little impact as possible on our supply chains. In preparing the document sent to the Revenue Agency, we discussed with the other interested Associations, from Confitarma to Federagenti, and we are confident that they will share the contents, but May 15, with the season summer now upon us, we sent our observations to the Agency together with ANPAN“.

With Resolution 2/E, the Revenue Agency had established that, as regards the VAT non-taxability regime, it is necessary to refer to the actual use and no longer to the simple enabling of the unit. Therefore to navigations that include “international waters”, with sections outside the limit of 12 nautical miles measured from the baseline. The criterion chosen is the historical one: in order to be able to operate exemptly in the current year, the vessels must have made more than 70% of the total commercial voyages carried out on the “high seas” in the previous year.

Already in February, March and then in a detailed note dated 15 May, UCINA Confindustria Nautica and ANPAN asked the Revenue Agency for some clarifications on which the offices of the Financial Administration have been working for several weeks. In particular that:

  1. the new system introduced by Resolution 2/2017 will be implemented on a non-retroactive basis;
  2. a declaration from the shipowner is required for all those cases of “discontinuity” in which it is not possible to reconstruct historical data on the previous year (unit under construction or new, or that has changed owner or charterer, or the route of line, etc.);
  3. a procedure for rectifying the billing originally made is established, without the application of penalties if the shipowner or user who has made the aforementioned declaration subsequently communicates that the condition relating to actual navigation on the “high seas” has not been satisfied;
  4. the trips to be taken into consideration are only commercial ones, excluding placements and repositioning;
  5. it is explicitly recognized that the costs of moving the unit, even if unrelated to the 70% calculation, as they are functional to the commercial activity, are in any case covered by the non-taxable regime (as is done in France);
  6. with regard to the existence of prevalent navigation on the “high seas” (or the related declaration), the responsibility of the shipowner is established and the non-sanctionability of the supplier.

Genoa, 18 July 2017



UCINA CONFINDUSTRIA NAUTICA is the sector association belonging to Confindustria which since 1967 has had the institutional representation of the entire nautical supply chain – from shipbuilding to components, from services to tourism. With 312 member companies, it represents over 80% of the national nautical industry and 65% of the total turnover and works for the growth of the nautical sector, also through the legislative proposal, the collection and dissemination of sector data, the diffusion of the culture of the sea and the development of nautical tourism.

UCINA operates at an institutional level as a subject of confrontation with political, social and government forces and adheres to Confindustria, Federturismo, the Federation of the Sea, the Industry Fairs Committee, the Edison Foundation, the Sustainable Development Foundation, sharing their principles and actions. At an international level, UCINA is present in the governing bodies of the world and European federation, ICOMIA and EBI.

In line with its aims of promoting the nautical sector, UCINA organizes, through the company I Saloni Nautici, the Genoa Boat Show, a leading international event and showcase for Made in Italy.



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