Tax Update Shipping & Offshore - March 2026
We are pleased to present the March 2026 edition of our Tax Update Shipping & Offshore.
The global maritime sector is undergoing a period of accelerated regulatory, fiscal and strategic change, with governments and international institutions introducing new frameworks that reshape investment conditions across shipping, ports, offshore energy and maritime services.
This month’s update highlights a series of significant developments, from the EU’s new Ports and Industrial Maritime Strategies to fresh offshore wind incentives in Finland, major fiscal reforms in India, Argentina and Morocco, as well as important tax, regulatory and labour‑market changes in the Netherlands and Malta. Together, these measures illustrate how rapidly the operating landscape is evolving and underscore the growing importance of aligning maritime activities with decarbonisation goals, strategic autonomy considerations and competitive tax regimes. This overview provides a concise snapshot of the most relevant changes and what they may mean for stakeholders across the maritime value chain.
As always, we aim to offer clear insights into developments shaping the fiscal and regulatory landscape for the global maritime sector.
Finally, good to know that the SBIE for mobile assets is still on the agenda. Absolutely relevant for the offshore maritime sector and we will update you as soon as possible. We are on top of these developments.
Enjoy the March 2026 update!
In this edition
- 1. EU: New Maritime and Ports Strategies
- 2. Finland: Offshore windfarms
- 3. India: IFSC GIFT City (Special Economic Zone)
- 4. Argentina: One-year extension and updated guidance for large investments incentive regime (RIGI)
- 5. Malta: New Rules for the Tax Treatment of Highly Skilled Individuals
- 6. Morocco: DGI Clarifies Finance Law 2026 Measures
- 7. Netherlands: flag exemption
- 8. Netherlands: tonnage tax policy decision
- 9. Netherlands: Dutch flag and equal pay?
- 10. Netherlands: new Dutch Residence Permit for Seafarers Clarified
- 11. General and the Netherlands: E-invoicing & digital reporting developments
1. EU: New Maritime and Ports Strategies
On 4 March 2026, the European Commission adopted two closely linked initiatives shaping future investment across ports, shipping and maritime manufacturing: the EU Ports Strategy and the EU Industrial Maritime Strategy. Together, these strategies set out how the EU intends to strengthen the competitiveness, resilience and sustainability of the maritime sector in the coming years.
Rather than creating a new dedicated funding programme, the Commission’s approach focuses on better mobilising and coordinating existing EU, national and private funding to support decarbonisation and strategic investment along the maritime value chain. Relevant instruments include the Connecting Europe Facility (CEF), InvestEU, Horizon Europe, the Innovation Fund, the European Defence Fund, and, where applicable, national EU ETS revenues, complemented by advisory services and de‑risking support to facilitate private investment.
Under the EU Ports Strategy, the Commission aims to improve access to EU financing for investments in port electrification, clean fuels, grid connections, digitalisation and security. The Strategy places particular emphasis on the role of small and medium-sized ports and seeks to accelerate permitting procedures for strategic energy and environmental port projects, reflecting ports’ growing role as logistics, energy and industrial hubs.
More information: link
The Industrial Maritime Strategy focuses on scaling investment in fleet decarbonisation, shipyard modernisation and advanced vessels, combining public funding, state aid tools and private capital. A key element is the creation of a new Industrial Maritime Value Chain Alliance, intended to better align public and private investment priorities and strengthen EU leadership in strategic maritime technologies and production capacity.
More information: link
KPMG can support clients across the maritime value chain with identifying relevant EU and national funding opportunities, structuring projects, and preparing funding applications, and can provide further insight into how these strategies translate into concrete funding pathways for specific investments. Please reach out to Betjes.Merijn@kpmg.com
2. Finland: Offshore windfarms
Government Proposal HE 29/2026 establishes a clear and investor‑friendly tax framework for offshore wind farms in Finland’s Exclusive Economic Zone (EEZ). The proposal reduces the property tax burden on offshore turbines and extends Finnish real estate and income taxation to offshore assets and activities in the EEZ. By harmonizing taxation with international rules and creating greater regulatory certainty, the government aims to significantly improve investment conditions, support ongoing and future offshore wind auctions, and strengthen Finland’s position as a competitive offshore wind market in the Baltic Sea.
3. India: IFSC GIFT City (Special Economic Zone)
We are happy to share an update from our Indian colleagues: IFSC GIFT City has rapidly emerged as a premier global hub for maritime finance, offering a uniquely compelling value proposition for ship leasing entities. As a designated special economic zone, IFSC provides exceptional fiscal incentives, including a 100% tax holiday and GST exemption on export of services, making it one of the most attractive jurisdictions globally.
The momentum in the ship leasing segment has been remarkable. In just two years since operationalization, 35 ship leasing entities have been registered in IFSC GIFT City, including leading global, a clear testament to growing international confidence in the ecosystem.
Building on this traction, the Government has reaffirmed its long-term commitment to positioning IFSC GIFT City as a globally competitive financial centre. Recently proposed reforms significantly enhance the attractiveness of the regime, including:
- Extension of the 100% tax holiday to 20 consecutive years out of 25 years (up from the current 10 out of 15 years)
- Concessional 15% tax rate on business income for the post–tax holiday period
- Introduction of anti-abuse safeguards to prevent misuse through splitting, reconstruction, reorganisation, or transfer of existing Indian businesses
Together, these measures place IFSC GIFT City among the most competitive financial centres worldwide, offering one of the longest tax holiday regimes combined with a globally acceptable minimum tax rate of 15%, fully aligned with OECD BEPS Pillar Two standards.
The underlying business momentum is equally strong. The number of vessels has already increased to 30 within a single year. The liberalised ship leasing framework, reinforced by enhanced fiscal incentives, underscores the Government’s clear, long-term vision for making India a maritime leasing powerhouse.
In case of questions please reach out to your contact within KPMG or to Nidhi Maheshwari directly: nmaheshwari@bsraffiliates.com
4. Argentina: One-year extension and updated guidance for large investments incentive regime (RIGI)
Decree No. 105/2026 extends the deadline to join the RIGI (RIGI is the Spanish acronym for Incentive Regime for Large Investments) regime by one year (from July 8, 2026) and introduces multiple adjustments to Decree 749/2024. These include updated sector definitions, stricter supplier import rules, revised investment thresholds, new rules for project expansions, an accelerated depreciation regime, clarified tax treatment of dividends, adjusted tariff exemptions, new foreign‑exchange and traceability requirements, voluntary supplier deregistration, updated sanctions, and the creation of a project evaluation committee. The decree also updates the oil & gas framework by redefining eligible sector activities. It now distinguishes between new onshore hydrocarbon developments and offshore exploration and production, each with separate minimum investment thresholds. Notably, offshore projects receive a significantly reduced investment requirement of USD 200 million, compared to USD 600 million for onshore developments, thereby expressly promoting offshore exploration and production within the RIGI regime.
Read a February 2026 report (Spanish) prepared by the KPMG member firm in Argentina.
5. Malta: New Rules for the Tax Treatment of Highly Skilled Individuals
The Tax Treatment of Highly Skilled Individuals Rules, 2026 has introduced revised criteria for benefitting from a 15% tax rate on qualifying employment income.
In terms of L.N. 20 of 2026, with effect from 1st January 2026, highly skilled individuals holding an eligible office (Eligible office - an employment or office where the employment, office, employee or the employer, or any combination thereof, is regulated, licensed or recognised by a competent authority referred to in the Schedules.) in terms of a qualifying contract of employment working within among others the following sectors, may elect to be subject to tax at 15% on the respective remuneration:
- Transport - Aviation and/or Maritime
- Offshore Oil and Gas Ancillary
The beneficial tax rate of 15% applies to individuals who have the requisite qualifications and at least 5 years of professional experience in the respective field, earning employment income of at least €65,000 from the respective employment/office. The benefit is applicable for a period of 5 years, commencing in the year in which a formal determination is issued, and may be extended for an additional two periods of 5 years each, subject to the respective conditions being maintained.
Applications are open for a 10-year period starting from 1st January 2026 till 31st December 2035. For further information, reach out to our Maltese colleagues.
6. Morocco: DGI Clarifies Finance Law 2026 Measures
Circular No. 737 (in French and as a PDF only) was published on 27 February 2026 on the DGI website. The Directorate General of Taxes (Direction Générale des Impôts, DGI) has published this circular to explain the tax provisions of Finance Law 50-25 for 2026, which is part of the structural tax reform (2023-2026). It includes relevant developments for the maritime industry.
Under the Moroccan Finance Law 2026, all payments made to non‑resident companies in connection with the operation of vessels deployed in international maritime transport are now fully exempt from Moroccan withholding tax. The exemption covers a broad range of income streams, including (i) charter hire under time‑charter, voyage‑charter and bareboat arrangements (“affrètement”), (ii) rental fees for the use of vessels, regardless of the charter structure, (iii) payments for technical or operational maintenance of vessels serving international routes, and (iv) all “remunerations analogues”, expressly including demurrage/surestaries and other ancillary service fees connected to the charter or rental contract.
The measure applies to vessels operating between Morocco and foreign ports and ensures that any remuneration linked directly or indirectly to the deployment, operation, or turnaround of such vessels is no longer subject to the previous 10% withholding. This broad exemption represents a significant reduction in the fiscal burden for international shipping operators and aligns Morocco with international maritime taxation standards.
7. Netherlands: flag exemption
The Dutch tonnage tax regime will again allow the use of a national exemption from the EU/EEA flag requirement in 2026.
As a result, vessels newly brought into operation during 2026 are not obliged to sail under an EU or EEA flag, as long as the shipping company operates at least one vessel that does carry an EU/EEA flag—whether through ownership, bareboat chartering, or crew and technical management arrangements.
This continued exemption is possible because the proportion of EU/EEA‑registered tonnage in the Netherlands increased over the 2022–2024 period compared with the preceding reference years 2021–2023.
8. Netherlands: tonnage tax policy decision
The Dutch Tax Authority has clarified that when a multipurpose seagoing vessel is chartered exclusively for seabed exploration activities, the ship qualifies as a vessel intended for seabed exploration for tonnage‑tax purposes. In such cases, both the shipowner and the charterer may apply the tonnage tax regime, including the asset‑and‑crew split, even if their respective activities differ. Each party determines its tonnage‑taxable profit based solely on its own personnel and investments—X on the navigation and operational components of the ship, and Y on the research‑related activities—without taking into account the workforce or assets of the other party. This ensures, according to the Dutch Tax Authority, a clear and equitable allocation of shipping income under the tonnage tax regime for vessels used in offshore research operations.
9. Netherlands: Dutch flag and equal pay?
The Dutch Minister of Infrastructure and Water Management has submitted to Parliament the report “The Flag Register and the Residence Principle: Economic and Strategic Value”, prepared by HCSS and Deloitte. The study was commissioned in response to recent rulings by the Netherlands Institute for Human Rights, which found that applying the residence principle—a wage system that ties seafarers’ salaries to the cost of living in their home country—constitutes unlawful discrimination when used on Dutch‑flagged vessels employing foreign crew.
These rulings have created substantial legal uncertainty. An NGO (Equal Justice Equal Pay) has issued a liability notice to the Dutch State, demanding retroactive wage equalisation for Indonesian and Filipino seafarers back to 2016, and many Dutch shipowners have received similar claims.
The report assesses the consequences of abolishing the residence principle and finds severe economic and strategic risks. If the Netherlands required all seafarers on Dutch‑flagged ships to be paid at Dutch wage levels, labour costs would rise sharply, damaging competitiveness in a global shipping market where many countries maintain similar wage structures. Researchers predict that 50–70% of the Dutch‑flagged fleet would reflag, leading to a major contraction of the Dutch maritime sector, loss of jobs, reduced economic activity, and weakening of the maritime cluster.
Strategically, a smaller Dutch fleet would significantly reduce the Netherlands’ ability to deploy vessels and crew in crises, conflicts, or emergencies. The loss of Dutch‑flagged tonnage undermines national security, supply‑chain resilience, and strategic autonomy at a time when more than 80% of global trade moves by sea. Dutch‑flagged vessels are essential assets because they fall under Dutch jurisdiction and can be mobilised by the government when needed.
The Cabinet acknowledges the findings and emphasises that maintaining the residence principle is important for preserving a level playing field in the international maritime sector. The government will conduct further research to determine how best to preserve the Dutch‑flagged fleet, protect maritime employment, and safeguard the strategic value of the Netherlands’ flag register.
Click here to read the full report in Dutch.
10. Netherlands: new Dutch Residence Permit for Seafarers Clarified
In close connection with the maritime sector, the Dutch government has introduced a new residence permit specifically for seafarers who, due to prolonged seafarer service, require a residence permit in the Netherlands. These changes are relevant for the maritime sector because of its international character.
For a long time, efforts have been made to create an appropriate residence permit for these seafarers, which will now be introduced as of 1 July 2026. From this date, a residence permit is required if someone stays in the Netherlands for more than 90 days to perform seafarers’ duties on board of a vessel in a Dutch harbor. The IND recently announced that the residence permit can be applied for as of 1 April, and more information is now available about the conditions, income requirements, and maximum duration of this permit.
The government has set a clear income requirement: seafarers must earn at least the standard wage for ultimately a deckhand according to the Maritime Labour Convention 2006. For this year the standard is set at 690 USD gross per month; the employment contract must show that this income is paid. The employment contract and the seaman’s book must be submitted with the application. The permit is linked to one specific vessel, and the number of seafarers on that vessel who receive a permit may not exceed the minimum crew required for that vessel. The residence permit for seafarers is limited to the actual period of work, with a maximum of 11 months. The permit cannot be extended beyond this period.
With this permit, it's allowed to perform seafarers’ duties on board of the vessel. It is very important that the work is limited to this, as the permit does not grant access to the Dutch labor market! All other work, including (not limited) for example, major maintenance, renovation, or construction of ships, is definitely not included and is therefore not permitted.
Lastly, it's important to note that seafarers who enter a Dutch seaport with the sea-going vessel and remain on board are exempt from the obligation to apply for a residence permit. This follows from the Schengen Borders Code, which stipulates that they are not subject to border checks at the seaport police checkpoint.
In case of further questions, please contact: Snieders.Heleen@kpmg.com
11. General and the Netherlands: E-invoicing & digital reporting developments
E-invoicing & digital reporting developments
Various countries worldwide have introduced or will introduce various e-invoicing & digital reporting developments. Here you can find the most recent updated KPMG E-invoicing Developments Timeline. If you would like to receive a monthly update on the latest developments, or if you would like to have a brainstorming session about the best way to implement a global, robust approach, please contact: Siem.Elene@kpmg.com
Limitation input VAT recovery right due to passive shareholding
Based on a Dutch Decree published in 2025, it is (even more) important for companies to pay attention to their input VAT recovery right. If a company holds shares in its directly held subsidiaries without performing any services/supply of goods towards these entities, a limitation of input VAT recovery may be in place. We recommend companies to assess their current VAT position and to optimize this to the extent possible.
