Tax Update Shipping & Offshore - July2026
In this pre-summer edition of our Shipping & Offshore Tax Update, we again discuss a number of interesting tax developments from the Netherlands and abroad. A notable theme is that various jurisdictions continue to modernise their maritime tax regimes in order to strengthen their competitive position. In this update, we consider, among other things, the recent reforms of the tonnage tax regimes in Sweden and Greece and the new tax facilities for shipping and commodity trading in Hong Kong.
We also look at tax developments in the offshore energy sector and discuss the recently published German guidelines on the concept of a permanent establishment, which include relevant insights for the shipping, offshore and construction sectors.
Finally, for our Dutch readers, we highlight an interesting WFR article by our Rotterdam colleagues Anouk Portengen and Frank Soentjens on the interaction between the Dutch fiscal unity regime and the tonnage tax regime.
We hope you enjoy reading this update.
Table of Contents
- 1. Sweden significantly expands tonnage tax regime
- 2. Hong Kong introduces new tax facilities for shipping and commodity trading
- 3. Greece proposes changes to tonnage tax regime and shipping tax incentives
- 4. Offshore oil and gas sector: tax incentives remain important
- 5. Germany updates permanent establishment policy: implications for shipping, offshore and construction projects
- 6. Professional literature (Dutch) – fiscal unity and the tonnage tax regime
1. Sweden significantly expands tonnage tax regime
One of the most relevant developments for the European maritime sector is the approval by the Swedish Parliament of a package of measures that substantially modernises the Swedish tonnage tax regime. The reforms are aimed at strengthening the competitive position of the Swedish shipping sector and better aligning the regime with the current EU State aid guidelines for maritime transport.
The changes include, among other things:
- broader possibilities for bareboat charter activities within the tonnage tax regime;
- expanded conditions for specialised vessels;
- adjustments to the vessel qualification criteria;
- improved possibilities regarding tax depreciation reserves.
These developments are also highly relevant from a broader European perspective, as several European countries are seeking to make their maritime tax regimes more attractive in order to retain or attract shipping companies and offshore businesses. The Swedish changes show that competition between European tonnage tax regimes remains very much alive.
2. Hong Kong introduces new tax facilities for shipping and commodity trading
Hong Kong has published a bill providing for tax facilities for shipping-related activities and physical commodity trading. With these measures, Hong Kong aims to further strengthen its position as an international maritime and trading hub.
This development fits within a broader trend in which various maritime hubs worldwide are introducing targeted tax facilities to attract shipping companies, shipping management companies and trading houses.
3. Greece proposes changes to tonnage tax regime and shipping tax incentives
The Greek government has published proposals that amend various parts of the existing tonnage tax regime. Although the foundations of the Greek tonnage tax regime remain intact, the proposals contain both increases in tax burden and new incentives for the maritime sector.
From 2026, the amounts due under the Greek tonnage tax will be increased annually by 4%. This increase applies for the period from 2026 through 2030 and affects both the regular tonnage tax and certain related contributions within the Greek shipping system. As a result, the tax burden for shipowners will gradually increase, while the underlying tonnage tax model remains in place.
Set against this increase are several measures aimed at strengthening the competitive position of the Greek and European fleet. The proposal extends various existing benefits to vessels flying an EU or EEA flag. This means that facilities traditionally available mainly to Greek-flagged vessels will become more broadly accessible to European shipowners that meet the relevant conditions.
In addition, the proposal includes further tax incentives for fleet renewal. Reduced tonnage charges are proposed for newly built vessels, for vessels brought under the Greek flag and for situations in which older vessels are replaced by younger tonnage. Investments in substantial conversions or modernisation of vessels may also qualify for tax relief, subject to conditions.
The proposals fit within a broader European trend in which maritime states are modernising their tonnage tax regimes and placing greater emphasis on sustainable investment, fleet renewal and equal treatment of EU-flagged vessels. At the same time, the changes are aligned with earlier discussions between Greece and the European Commission on the State aid design of the Greek shipping regime.
4. Offshore oil and gas sector: tax incentives remain important
Several countries are using tax instruments to stimulate investment in offshore energy projects.
In Trinidad & Tobago, targeted tax facilities have been introduced for smaller offshore gas fields that would not be sufficiently profitable without support. The facilities focus on fields with limited reserves and a relatively low expected return.
In addition, a recent IMF report indicates that Suriname expects significantly higher tax revenues from offshore oil production from 2028 onwards. According to the IMF, offshore oil will make an important contribution to future government revenues.
5. Germany updates permanent establishment policy: implications for shipping, offshore and construction projects
On 18 June 2026, the German Federal Ministry of Finance (BMF) published new guidelines on the concept of a permanent establishment (Betriebsstätte). The guidelines contain several relevant clarifications for the shipping, offshore and construction sectors; see also BMF: Final BMF letter on the administrative principles for the permanent establishment concept.
Key points
A seagoing or inland waterway vessel in operation does not, in itself, constitute a permanent establishment because there is no permanent connection with the surface of the earth.
- Permanently moored vessels and offshore units may, however, constitute a permanent establishment. The BMF refers, among other things, to hotel, residential, restaurant and storage vessels, as well as stationary energy installations and floating production and storage units.
- It is noteworthy that the BMF distinguishes between the vessel itself and the activities carried out with the vessel. An offshore vessel does not automatically constitute a permanent establishment, but construction or installation activities performed with the vessel may, in certain circumstances, give rise to a construction or installation permanent establishment.
- The mere fact that employees or contractors perform work on offshore installations or at a customer’s facilities does not automatically create a permanent establishment. The decisive factor remains whether there is sufficient power of disposal over the location.
- For construction and installation projects, German domestic law generally applies a six-month threshold. For treaty purposes, a twelve-month threshold often applies under Article 5(3) of the OECD Model Tax Convention. We note, however, that the BMF does not address specific offshore provisions in tax treaties, including so-called offshore clauses. These should not be overlooked in practice.
- Germany also confirms that mere construction or installation supervision does not, according to the German interpretation, automatically give rise to a construction or installation permanent establishment.
- When assessing construction and installation projects, multiple projects may be aggregated if there is sufficient economic and geographical coherence.
6. Professional literature (Dutch) – fiscal unity and the tonnage tax regime
For readers who would like to explore the Dutch tax treatment of shipping activities within group structures in more detail, we recommend a recent article by our colleagues Anouk Portengen and Frank Soentjens in Weekblad Fiscaal Recht (WFR). The article discusses the interaction between the Dutch fiscal unity regime and the tonnage tax regime and contains valuable practical insights for the maritime sector.
Anouk and Frank both work at our Rotterdam office and are part of the team of tax specialists that is active in the broader maritime sector. From their respective areas of technical focus, they regularly deal with complex tax issues in the shipping and offshore industry.
The article can be found via the WFR page on TaxLive, where the different WFR issues are made available. Source: Weekblad Fiscaal Recht (TaxLive) [taxlive.nl]
