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State Aid

PR(08)75: The Authority gives green light to new Norwegian Tonnage Tax


Yesterday the EFTA Surveillance Authority decided to approve the new Norwegian Tonnage Tax scheme.

The new Tonnage Tax system is an exemption regime, under which shipping income is tax exempt on a permanent basis. Instead of paying corporate tax on profit generated by eligible maritime activities, eligible undertakings will pay a tonnage tax. Under this system, the ship owner pays an amount of tax linked directly to the tonnage operated. Such tax is payable irrespective of the company’s actual profits or losses.

Undertakings opting for the new regime must remain within the system for a minimum period of ten years. In addition, all companies belonging to the same group must opt for the regime.

In addition to the new Tonnage Tax system, the Norwegian authorities also notified measures related to the transition from the prior Tonnage Tax system to the new one. These measures allow up to one third of the deferred tax to be set aside to an environmental fund which can be used for different kinds of environmental investments. Furthermore, up to two thirds or more of the deferred tax may be subject to corporate tax over ten years with a 10% linear depreciation. Undertakings will, however, only benefit from these transitional measures if they opt for the new Tonnage Tax system.

The Authority has considered that both the transitional measures and the amended Tonnage Tax regime amounted to state aid but considered that such measures were compatible with Article 61(1) and 61(3)(c) in conformity with the Guidelines on state aid to maritime transport.


For further information, please contact:


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

Ms. Marianne Clayton
Officer, Competition and State Aid Directorate
Tel. (+32)(0)2 286 18 23



Brussels, 4 December 2008

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