Tonnage Tax Regimes
The notional tonnage-based charge that replaced corporation tax on shipping profits, how the main national schemes differ, and how each treats charter tonnage.
A tonnage tax regime replaces ordinary corporate income tax on shipping profits with a notional profit calculated from the net tonnage of the ships a company operates, charged regardless of what the company actually earned. Qualifying companies elect into the regime for a fixed minimum period and pay tax on that notional figure.
The regimes exist as the traditional maritime States’ answer to open-registry tax neutrality: rather than lose tonnage to a no-tax jurisdiction, the State offers a low and predictable charge to companies that keep a managed fleet, and usually attaches conditions on training, on flag and on the proportion of chartered-in tonnage. Those chartered-in limits are where the regimes intersect with bareboat charter and time charter structures, since a company’s mix of owned and chartered ships can determine whether it qualifies at all.
The full article will cover the United Kingdom, Greek, Cypriot, Dutch and Norwegian schemes, the qualifying conditions and election periods in each, the training obligations, the treatment of bareboat-chartered-in and bareboat-chartered-out tonnage, and the European Commission State aid guidelines that shape the schemes’ common features.