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Tax provisions - Harmonization of laws - Turnover taxes - Common system of value-added tax - Exemptions provided for in the Sixth Directive - Exemption of the supply of goods for the fuelling and provisioning of vessels - Conditions
( Council Directive 77/388, Art . 15(4 ) )
Article 15(4 ) of the Sixth Directive ( 77/388 ) exempting from value-added tax the supply of goods for the fuelling and provisioning of vessels must be construed to the effect that only supplies to a vessel operator of goods to be used by that operator for fuelling and provisioning are to be regarded as such, and not supplies of those goods effected at a previous marketing stage . However, there is no requirement that the goods should be actually loaded on board the vessels at the time of their supply to the operator, so that the storage of the goods after delivery and before the actual fuelling and provisioning operation does not cause the benefit of the exemption to be lost .