The Supreme Court re-affirms that the refueling and provisioning operations of vessels used for navigation on the high seas benefit from the non-taxable regime only if it concerns final transfers of goods directed towards the shipowner , while the preferential regime does not extend to earlier commercial stages. If the supply is made to an intermediary acting in his own name rather than the shipowner, according to the Court, the loading of the goods on board is relevant.
Source: eutekne.info