Norwegian Tonnage Tax

The Norwegian Ministry of Finance recently notified EFTA about continuing the Norwegian tonnage tax system until 31 December 2026 (the current EFTA approval expire 1 July 2017). While expanding the tonnage tax to some vessels used for windmill installation, it is also worthwhile noting that some restrictions will be proposed, mainly;

  • maximum 50% of the total tonnage in a group can be bareboat chartered to others and strategic management of the bareboat charter tonnage must be inside the EEA area.
  • rental of tonnage under time charter and voyage charter is limited to 90% of total tonnage in the group. This applies for vessels registered outside the EEA area.
  • the limitation of bareboat charter and time charter mentioned in the two previous bullet points does not apply for contracts already entered into.
  • vessels without its own propulsion system mainly operating on lakes and rivers are proposed to not constitute qualifying assets.

We at Brækhus are of the opinion that the inclusion of some wind turbine installation vessels should be regarded as positive, especially as the previous distinction between some qualifying installation vessels and some non-qualified installation vessels could be regarded as incoherent with the general principles and intentions under the current regulations. On the other hand, this may be an issue for;

  • groups mainly owning, and not operating vessels and
  • groups that mainly charter vessels registered outside EEA.

All in all it is a limitation of the currently applicable and relatively liberal rules.

We at Brækhus are available to discuss these changes and their consequences for your Group.


Antonio Holstad
Nils Eriksen
John Spissøy