The main goal for the thesis is to evaluate if the Danish tonnage tax scheme is in compliance with the European Commissions guidelines regarding state aid to sea transportation and Acts and to find out, if the Danish tax scheme is to strict compared to the EU-guidelines. The Danish tax scheme was introduced for the first time in 2002 and has since developed throughout the years. The benefit of using the tonnage tax scheme to calculate the taxable income based on the ships net tonnage multiplied by a fixed amount, in stead of the general tax rules. Besides the advantage of lower taxes, the tonnage scheme allows the shipping companies to make commercial decisions based on needs instead of tax incentives. Shipping companies have to meet certain criteria’s to use the tax scheme. Only income from ships that transport passengers and goods by sea, with ships that are above 20 tons, and operated strategically and commercially from Denmark can fall under the tax scheme. Besides the shipping companies have a lock-in period of 10 years, when the scheme is chosen. Furthermore the shipping companies have to maintain or increase the share of ships registered in a member state, in order to get full advantage of the scheme. The thesis shows that the Danish tonnage tax scheme seems to be too strict compared to the Commissions guidelines on a few, but central points. The first is what activities that can comply with the law compared to the guidelines. The second is, what can be defined as a destination. The Danish tax authority interprets the law, so only activities that fulfill a need for transport can comply with the scheme. Transportation by sea that start and end the same place will not fall under the tax scheme. This interpretation is much more strict then the Commissions interpretation, and allows activities, that are usually paid for, which seems to be a much more loose interpretation. Also the destination term is object for different interpretation. Also in this situation the Commission seems to have a more loose interpretation compared to the Danish tax authorities, that only allows ports or offshore installations as destinations, whereas the Commission will allow destinations at sea as an destination. Side 3 af 45 It seems that Danish tonnage tax scheme is unnecessarily strict compared to the guidelines, which may make it less attractive for shipping companies to run their business from Denmark.
31 dec. 2016
Aarhus University. BSS. Department of Economics and Business Economics