All material subject to strictly enforced copyright laws. © 2022 ITR is part of the Euromoney Institutional Investor PLC group.

Norway: Alterations of the Norwegian tonnage tax regime


Ragna Flækøy Skjåkødegård

The Ministry of Finance recently published its letter of notification of the tonnage tax regime to the EFTA Surveillance Agency (ESA), outlining the following alterations in the existing tonnage tax regime:

Bareboat chartering out

The following restrictions/alterations are introduced for bareboat chartering out:

  • Bareboat chartering out is limited to 50% of the total tonnage of the company group's fleet within the tonnage tax regime during an income year. The Ministry of Finance suggest that there should be an option to measure the bareboat chartered out fleet over a period of four years.

  • Bareboat charters must not exceed a contractual period of 5 (+3) years, i.e. five years with the option to extend for three years. Bareboat contracts exceeding 5+3 years will thus constitute disqualifying assets.

  • Strategical management of all vessels chartered out on bareboat terms must be performed from within the EEA.

The Ministry states that intra-group bareboat chartering out will be allowed "unconditionally". There are no limitations introduced for chartering in on bareboat terms.

The limitations are, as a starting point, applicable to new bareboat chartering out contracts. Tonnage chartered out on existing contracts, including options to extend for up to three years, will not be included in the limitation introduced. However, this transitional rule will not apply to what the Ministry calls "long-term contracts", defined as contracts of a duration of more than five years. Long-term contracts will thus be disqualifying for the tonnage tax regime.

Voyage charter/time charter

The Ministry notifies a limitation of 90% on the chartering in of non-EEA flagged vessels on time charter or voyage charter terms. Any limitations will be measured on a yearly basis, but counting the tonnage chartered out for each day of the year. The tonnage will be measured on a company group level. The limitation will only apply to new chartering in contracts.

Inclusion of windmill farm vessels

The Ministry of Finance notifies that vessels involved with construction, maintenance, repair and disassembly of windmills at sea are qualifying for the tonnage tax regime. Up to now, the windmill farm vessels have only constituted qualifying assets to the tonnage tax regime if they have been used in transportation assignments. The extension is notified to take effect from January 1 2017, and the extension was adopted by the Parliament in December 2016, but is awaiting the approval from ESA.

The extension does not comprise windmill farm vessels operating in Norwegian internal waters or Norwegian territorial waters.

Exclusion of vessels not being self-propelled and operating in foreign inland waterways

The Ministry of Finance also notifies that vessels that are not self-propelled and operating mainly in foreign inland waterways should not qualify for the tonnage tax regime. Vessels that are not self-propelled and operating mainly in Norwegian waterways are disqualifying according the current tonnage tax regime.

Except for the extension regarding windmill farm vessels, the alterations are planned to take effect from July 1 2017.

Ragna Flækøy Skjåkødegård (, Oslo


Tel: +47 23 27 96 00


More from across our site

This week European Commission officials consider legal loopholes to secure minimum corporate taxation, while Cisco and Microsoft shareholders call for tax transparency.
The fast-food company’s tax settlement with French authorities strengthens the need for businesses to review their TP arrangements and documentation.
The full ALP model will be adopted through a new TP regime, which is set to boost the country’s investments and tax certainty.
Tax professionals have called on the UK government to reconsider its online sales tax as it would affect the economy at the worst time.
Tax professionals have called on companies to act urgently to meet e-invoicing compliance targets as the EU plans to ramp up digitisation.
In the wake of India’s ambitious 25-year plan for economic growth, ITR has partnered with leading tax commentators to discuss what the future will look like for India and for the rest of the world.
But experts cast doubt on HMRC's data and believe COVID-19 would have increased the revenue shortfall.
EY’s plan to separate its auditing and consulting businesses might lessen scrutiny from global regulators, but the brand identity could suffer, say sources.
Multinationals are asking world leaders to put a scale on carbon pricing to tackle climate change at the 48th G7 summit in Germany, from June 26 to 28.
The state secretary told the French press that the country continues to oppose pillar two’s global minimum tax rate following an Ecofin meeting last week.
We use cookies to provide a personalized site experience.
By continuing to use & browse the site you agree to our Privacy Policy.
I agree