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Netherlands: EC approves changes to tonnage tax regime

Netherlands: EC approves changes to tonnage tax regime

The European Commission approved, under EU state aid rules, the extension and expansion of three amendments to the Dutch tonnage tax regime until 31 December 2028.


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Originally approved in 2009 and 2010, the three measures concern:

  • A reduced tonnage tax rate for large vessels exceeding 50,000 net tons
  • A reduced tonnage tax base for ship management companies
  • Application of the tonnage tax regime to cable-laying vessels, pipeline laying vessels, research vessels, and crane vessels

In order to obtain the EC’s approval, the Dutch authorities committed to change the tonnage tax law. The Dutch authorities confirmed that certain changes are to be implemented in the Dutch tonnage tax regime by 1 January 2020, including:

  • Introduction of an EU/EEA flag-link requirement for ship management companies
  • A minimum entry requirement for taxpayers with respect to vessels newly acquired or managed by 1 January 2020—namely, to own/manage at least one EU/EEA flagged vessel
  • A 50% cap on the revenues of ancillary activities
  • Satisfying at least one of the required conditions for ships held in time and voyage charters—
    • In addition to time and voyage chartered vessels equipped and manned by other companies, the tonnage tax beneficiary must also have in its fleet vessels for which it provides crew and technical management, as long as such vessels constitute at least 20% of the total tonnage taxed fleet,
    • The share of the vessels that are both non-EEA and time / voyage chartered does not exceed 75% of the beneficiary's fleet under tonnage tax, or
    • At least 25% of the beneficiary's entire fleet is EEA-flagged in order to apply for the tonnage tax regime

Read a September 2019 report prepared by the KPMG member firm in the Netherlands

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