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V1152-18 8 May 2018 · SG de Impuestos sobre el Consumo Criterion in force
IVA · perfeccionamiento activo

Deliveries of a vessel under inward processing or free zone regimes may be exempt from VAT

A shipyard has requested a ruling on the taxation of the sale of a vessel constructed under inward processing, as well as subsequent transfers via financial leasing and free zones. The DGT has determined that these operations may be exempt or not subject to VAT, depending on whether export requirements are met or if they are linked to specific customs regimes.

The question raised

Taxation of the sale of the vessel by the consultant to the banking entity, as well as the financial lease subsequently carried out by the banking entity in favor of the Economic Interest Group.

The DGT's ruling

The construction and transfer of the vessel constitutes a supply of goods, as does a financial lease if it transfers powers of disposal. If the decoupling from active perfection is carried out through an exempt supply for export, there is no operation assimilated to an import. In chain sales, deliveries subsequent to the exempt supply for export are not subject to the tax. If linked to a free trade zone, successive deliveries are exempt as long as the good remains under said regime.

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