The amount of packaging and containers containing the goods is excluded from the taxable VAT base in the event that ‘the reimbursement upon return has been expressly agreed” (art. 15 paragraph 1 n. 4 of Presidential Decree 633/72). Otherwise, in fact, the transfer of such packaging would have an ancillary nature and the relative considerations would contribute to forming the taxable base of the main transaction under the conditions established by art. 12 of Presidential Decree 633/72.
Source Eutekne
