Europaudvalget 2016-17
EUU Alm.del Bilag 270
Offentligt
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4. januar 2017
ERHVERVSMINISTERIET
Slotsholmsgade 10-12
1216 København K
Tlf.
33 92 33 50
Fax.
33 12 37 78
CVR-nr. 10092485
EAN nr. 5798000026001
[email protected]
www.evm.dk
Danish views on Tonnage tax, the maritime sector and state aid issues
Dear Commissioner Margrethe Vestager,
Following the recent debate on maritime taxation in Denmark, I wish to
draw your attention to a number of important issues regarding the interna-
tional competitive situation of the maritime industry, as the Danish and
European companies are facing strong competition from countries outside
of the EU.
I shall address the Danish challenges concerning mobile offshore drilling
rigs and vessels (possible extension of the Tonnage tax scheme), taxing of
personnel on off shore construction vessels (DIS), and the Maritime
Guidelines on state aid in respect to the definition of the destination crite-
ria.
Further, we are awaiting the Commission’s response to a notification re-
garding an extension of the scope of the Danish Tonnage tax in respect to
specialized ships. The Danish Authorities has previously forwarded doc-
umentation on the matters to the Commission services.
The Danish tonnage tax scheme
Mobile drilling rigs and drilling vessels
The current Danish tonnage taxation scheme is dedicated to ensure the
competitiveness of Danish ships and ship owners globally. The global
market is characterized by high mobility between flag States and the Dan-
ish tonnage tax scheme seeks to match the Danish conditions with the
conditions offered by other leading international shipping nations.
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The framework of the Danish tonnage tax consists of regulation approved
by the Commission under the present EU guidelines. However, the Dan-
ish Government has taken a political decision to strive to extend the ton-
nage taxation scheme to include mobile drilling rigs and drilling vessels,
though a bill has not yet been introduced before the Parliament. At the
earliest, this might take place in February 2017. A preparatory meeting
took place between the Commission and the Danish Authorities on the 5
October 2016.
Globally, tonnage taxation is a popular way of attracting state income. In
2007, Singapore extended its tonnage taxation scheme to include mobile
drilling rigs and drilling vessels. Presently, this has led to huge differ-
ences in taxation of mobile rigs and vessels on a global scale. As an ex-
ample the current Danish tonnage taxation scheme being in the range of
DKK 10 million/unit, while the change of the Singaporean tonnage taxa-
tion in 2007 has led to an annual tax rate in Singapore in the range of
DKK
50,000/unit.
These tax differences increase Danish ship owners’ incentive to register
existing and new mobile drilling rigs and drilling vessels under e.g. the
Singaporean flag. In order to anticipate the global competitive situation,
we believe that the maritime guidelines must include drilling rigs and
ships in the tonnage taxation regulation on terms similar to international
regulation on transport by sea. Namely because:
• It is possible to register a vessel outside the EU, even though it operates
in the EU or competes in the world against EU units.
• The competitive situation is directed towards ship registers outside the
EU – only 3.5 per cent of the vessels are currently flying an EU flag or
owned within the EU/EFTA.
• The competitive situation is characterized by the major part of “drilling
rig vessels” being registered in registers in Liberia, Marshall Islands, Pan-
ama, Vanuatu, Singapore and Bahamas. E.g. because Singapore offers
attractive taxation schemes, Liberia does not levy any tax.
Ongoing registration outside of DK/EU will have an impact on employ-
ment and shore-based activities. The EU risks losing specialized know-
how. On this note I strongly urge the Commission to establish grounds for
a state aid approval of an extension of the Danish tonnage tax system.
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Danish Ship Register (DIS)
The Association of Danish Shipowners has pointed at a similar challenge
for the conditions of competitiveness of the maritime sector in Denmark.
Most shipping nations have a special tax regime for personnel on ships. In
Denmark the tax regulation for personnel on ships is regulated in the Dan-
ish Ship Register (DIS). However, offshore construction vessels are not
presently part of the Danish DIS taxation regime. Hence, Danish offshore
construction vessels are not operating on a level playing field with respect
to personnel tax compared to other nations where personnel on such ves-
sels are covered by more favorable tax regulations.
Thus, the need to explore possibilities for an adjustment of the tax regime
for personnel on offshore construction vessels is of great importance.
The definition of the destination criteria in the maritime guidelines
In addition, I would like to draw attention to another important issue; the
carriage of passengers or goods by sea between a port and a (non-fixed)
destination described in the Maritime Guidelines. In my view it ought to
be possible to include the carriage of passengers or goods by sea between
a port and a (non-fixed) destination at the high seas, e.g. another ship, in
the Maritime Guidelines. The Danish Government therefor strongly urges
the Commission to expand the definition of “maritime transport”.
Amendment of the Tonnage tax - Specialized ships
Finally, let me draw your attention to the pending Danish State Aid noti-
fication SA.45300-DK- RDO - Amendment of the Danish Tonnage Tax
scheme. I am looking forward to the Commission response on the matter
in the beginning of 2017. Hopefully, a solution where we can obtain the
Commission’s approval for the amendment can be found.
I look forward to a continuous constructive dialogue with you on these
and other important Danish issues in the future.
Yours sincerely,
Brian Mikkelsen
Minister for Industry, Business and Financial Affairs
Denmark