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V5263-16 13 December 2016 · SG de Fiscalidad Internacional Criterion in force
IRNR · arrendamiento a casco desnudo

Exemption applies to bareboat charter of vessels in international navigation

A Manx resident asks whether a bareboat charter of a recreational vessel operating in the Mediterranean is exempt. The DGT confirms that exemption applies if the vessel is used in international maritime navigation.

The question raised

Question posed: Admissibility of the exemption provided for in Article 14.1.g) of the consolidated text of the Non-Resident Income Tax Law to the income obtained from leasing activities.

The DGT's ruling

The exemption under Article 14.1.g) of the TRLIRNR applies to income from the leasing, assignment, or transfer of bareboat vessels used in international maritime navigation. The definitions of international navigation under the VAT Act do not apply, as the TRLIRNR does not refer to said regulation. Following the OECD model, international navigation is that which is carried out between points located in different States.

Apply this to a real case

What is published here, applied to a company or a specific case. The first meeting is free.

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