How the DGT's position has evolved
Current position
Private recreational navigation is defined by non-commercial purposes and is distinct from the provision of services for consideration. Vessels engaged in commercial activities, such as passenger transport, professional diving, or dive taxi services, do not engage in private recreational navigation. In these commercial cases, the use of diesel allows for the exemption from the Hydrocarbons Tax or the refund of quotas, provided that the fuel incorporates the regulatory tracers. For unleaded gasoline, only the exemption applies, not the refund of quotas.
The DGT's position remains constant regarding the distinction between recreational navigation and commercial activity. Rulings confirm that any service provided for consideration excludes the recreational nature. The only relevant clarification is that the exemption for unleaded gasoline does not entail a refund of quotas, unlike diesel.
Turning points
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Specifies that for unleaded gasoline in commercial activities, the refund of quotas paid is not applicable, limiting this benefit solely to diesel.
Analysis based on 11 of 13 rulings with a stated position. Updated 27 September 2026.