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State Aid

State aid: Changes to the transitional rules of Norwegian Tonnage Tax scheme approved



Today the Authority has approved changes to the transitional rules of the Tonnage Tax Scheme. The new transitional measures will enter into force as of the income year 2010 and deal with the phasing out of an old tonnage tax scheme.

In 2008, the Authority approved the new Tonnage Tax Scheme which is now in place in Norway. According to that scheme, shipping income is tax exempt on a permanent basis and only a tonnage tax related to the ship's tonnage is due. In addition to the new Tonnage Tax scheme, the Norwegian authorities had notified transitional measures which laid down rules on the change from the the previous tonnage tax regime to the new one.

The Norwegian Supreme Court, however, held in a judgment of 12 February 2010, that those transitional rules breached the Norwegian Constitution because they applied a fiscal measure retroactively. The Norwegian authorities then adopted new transistional measures to comply with that judgment and notified them to the Authority.

The Authority has taken the view that the notified changes to the transitional rules are compatible with the functioning of the EEA Agreement.


For further information, please contact:


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

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