Italy confirms no 22% VAT on a new resident's yacht import

Does a corporate-owned yacht still qualify for Italy's new-resident VAT relief?

Yes, provided the individual has economic availability and effective control over the asset, the Agenzia delle Entrate confirmed in Ruling No. 105/2026 - the first time a corporate wrapper has been confirmed not to defeat the relief on its own.

In Ruling No. 105/2026, published on 25 May 2026, the Agenzia delle Entrate answered a UK resident planning to move to Italy in 2026 and elect the flat-tax regime for new residents under Article 24-bis of the income tax code. The taxpayer owned a large pleasure yacht flagged in the Isle of Man and held through an Isle of Man limited partnership in which the individual controls more than 99.99% of the capital. The question was whether Italian import VAT, charged at the 22% standard rate, would fall due when the yacht was brought in for good. The Agency said no, provided the conditions are met, grounding the answer in Council Directive 2009/132/EC on relief for personal property imported on a transfer of normal residence.

The Agency noted that Italy has passed no dedicated law implementing that directive, but held that its terms are unconditional and precise enough to apply directly. The relief covers personal belongings, and the Agency accepts that a privately used pleasure craft qualifies as such. For an owner, the practical headline is that a lawful VAT-free entry point into the EU exists for relocations from third countries, and Italy has now set out on the record how it reads the test.

Why the holding company did not sink the claim

The novel part is the treatment of ownership through a company. The Agency clarified that possession, for the purposes of the relief, means economic availability and effective control over the asset rather than formal legal title, citing settled European Court of Justice case law. On that reading, a yacht held through a foreign partnership can still qualify where the individual genuinely controls and uses it. The Agency also applied the six-month rule, requiring that the vessel was in the person's possession and used at the former residence for at least six months before the move, and treated the Isle of Man and the United Kingdom as a single fiscal territory under their 1979 Customs and Excise Agreement, so the third-country origin was not in doubt.

Most yachts of this size are owned through special-purpose vehicles, not in a principal's own name, so this is the first time the Agency has confirmed that a corporate wrapper does not by itself defeat the personal-import relief. That widens the door for high-net-worth buyers who never hold title directly. The relief is not automatic, though: the Agency stressed that genuine control and personal use must be proven on the facts, which puts the burden on clean documentation of ownership, usage logs and the timing of the residence change.

The twelve-month string and what it costs to break it

The exemption comes with conditions. As PG Legal reads the directive, any commercial use of the yacht within twelve months of the definitive import, including letting it on charter, forfeits the relief and triggers recovery of the VAT together with interest and penalties. The Agency's own note in Fisco Oggi adds that a VAT exemption on import does not carry a customs-duty exemption with it. That is assessed separately by the Customs Agency. The six-month prior-ownership test and the requirement that the move be a genuine transfer of normal residence both remain live points a tax authority can revisit later.

For a buyer the arithmetic is direct: 22% of the hull's value set against a one-year freeze on chartering and a real paperwork burden. On a yacht valued in the tens of millions, the saved import VAT dwarfs a year of forgone charter income for an owner who intends private use anyway. For an owner who was counting on charter to offset running costs, it is a genuine trade to weigh. Paired with the flat-tax regime, whose principal charge rose to EUR 300,000 from EUR 200,000 on 1 January 2026, the ruling sharpens Italy's pitch to relocating owners against Monaco, Malta and other Mediterranean bases.