HMRC document 744c 2011 sets out requirements for qualifying vessels and in section 6.4 it clearly states that repair and maintenance of qualifying vessels is zero rated, provided that conditions specified in 6.4 & 6.5 are met. Paint appears to satisfy these conditions.
However, section 7.5 goes on to specifically exclude the following items: “bulk materials such as: adhesives, chemicals, fabrics, inhibitors, metals, oils, paints, solvents and thinners etc.”
