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Performance health and care services rendered to migrants, the homeless, asylum seekers

Article. 10, No 27-b) of Presidential Decree of 26 October 1972, n. 633, provides for, among other benefits, exemption from VAT of health and social services, home care or outpatient, community, and the like made in favor of, among other things, "migrants, homeless, asylum seekers" made by bodies governed by public law, recognized by health care institutions that provide public assistance or by charitable organizations and social welfare NGO. It was
asked the Inland Revenue if the exemption applies when the three conditions coexist, homeless migrants and asylum seekers, or the three types of subjects separately.
The Agency, with the resolution N. 238 / E, August 26, 2009 , based on a literal interpretation of the rule concludes that the exemption from VAT for social and medical services, home care or outpatient, community, and the like made in favor of migrants, homeless , asylum seekers, only applies when all three conditions coexist. This means that the social and health services made in favor of migrants who are not even homeless people and asylum seekers are serving the ordinary rate of VAT.