Alternative proofs related to export sales: the so-called “manifesto di carico” – Supreme Court Judgment No. 6584 of March 12, 2024

The Italian Supreme Court, with judgment no. 6584 dated March 12, 2024, stated that the so-called “manifesto di carico”, endorsed by the customs office of exit, is a valid alternative proof of the export sale, allowing the application of the VAT exemption regime on the basis of the Article 8, paragraph 1, letter b) of the Italian Presidential Decree no. 633/1972 (i.e., “indirect” export sales – with transport carried out by or on behalf of the foreign purchaser).