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.

The Budget Law for 2026 contains two provisions introducing the obligation to withhold tax at source in situations that also affect the yachting sector. Specifically, these provisions require withholding tax to be applied in cases of payment of commissions to maritime brokers and payment of fees deriving from the provision of services and the sale of goods carried out in the course of commercial activities.

In December 2025, two legislative provisions of particular relevance were issued for those intending to invest in real estate in Italy. In particular, Law No. 182/2025 introduced a regulatory provision relating to the transfer of real estates that had previously been donated, while Budget Law No. 199/2015 introduced important new provisions on the taxation of income deriving from the rental of real estates through short-term rental contracts.

In general, issues relating to VAT management, including procedures for recovering VAT credits, are of great importance to all businesses. A frequent issue arises in relation to how foreign entities with a permanent establishment in Italy can request a VAT credit refund.

In its Answer No. 10 of 15 July 2025, the Italian Revenue Agency clarified a doubt that had arisen regarding the obligation for shipowners who are individuals acting outside the scope of a business, art or profession to act as withholding tax agents.

We have already addressed the issue of VAT treatment of leasing contracts entered into by private shipowners (so-called B2C transactions) on several times. The relevant legislation, which regulates non-short-term leasing contracts for yachts to private individuals in general, is contained in Article 7-sexies, paragraph 1, letter e-bis) of Presidential Decree No. 633/1972, and in Revenue Agency Provisions No. 341339/2020 and No. 151377/2021.