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State Aid

The Authority approves changes to Norwegian Special Tax System for Shipping - PR(10)44



The EFTA Surveillance Authority has today approved a change to the Norwegian Special Tax System for Shipping (”the tonnage tax”).

By a decision dated 3 December 2008, the Authority approved the current tonnage tax system. Instead of paying corporate tax on profit generated by eligible maritime activities, the shipping companies pay a tax calculated with reference to the ships' tonnage.

Shipping companies often operate in international markets and therefore have income and costs in different currencies. In order to limit the impact of fluctuations in currencies, companies enter into currency hedging agreements. In December 2009, the Norwegian authorities notified an amendment to the tonnage tax system whereby currency hedging agreements connected to maritime activities will be included in the tonnage tax regime and treated in the same way as shipping revenues. In other words a profit will be tax exempted and a loss will not be tax deductible.

The amendment will enter into force as of the income year 2010.

The Authority has taken the view that the notified change is compatible with the functioning of the EEA Agreement.


For further information, please contact:

Mr. Per Andreas Bjørgan
Competition and State Aid Directorate
tel. (+32)(0)2 286 18 36


Mrs. Marianne Clayton
Senior Officer
Competition and State Aid Directorate
tel. (+32)(0)2 286 18 23

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