CENTRO INTERNAZIONALE STUDI CONTAINERS
ANNO XXXVIII - Numero GIUGNO 2020
STATE AID: COMMISSION APPROVES ITALIAN TAX MEASURES FOR
The European Commission has approved under EU State aid rules
the prolongation until end 2023 of various Italian support measures
for maritime transport under Italy's "International Registry"
scheme. The scheme encourages shipping companies to register their
ships in Europe and so ensure higher social, environmental and
Italy has also committed to a number of changes to its scheme to
avoid undue competition distortion as well as to prevent any
discrimination between shipping companies and registries of
different European Economic Area (EEA) States.
Under the "International Registry" scheme, shipping
companies are granted a corporate tax reduction and other benefits.
Following the changes to which Italy has committed, the special
corporate tax reduction for shipping companies will be applied to a
- core revenues from shipping activities, such as cargo and
- certain ancillary revenues that are closely connected to
shipping activities (capped at a maximum of 50% of a ship's
- revenues from towage and dredging, subject to certain
The Italian measure, as amended and approved today, requires
that if a shipping company wants to benefit from the "International
Registry" regime, at least a large part of its fleet flies the
flag of an EU or EEA State.
- bareboat charter-out and time and/or voyage charter-in
activities, subject to a number of conditions.
In this respect, the Italian authorities have committed to
extend the benefits of the scheme to all eligible ships that fly an
EEA flag. This will prevent any discrimination between shipping
companies and registries of different EEA States and preserve
internal market rules on freedom of establishment.
The Commission assessed the amended measures under EU State aid
rules, in particular its Guidelines
on State aid to maritime transport. It concluded that, in light
of commitments to which Italy will have to comply within seven
months from the adoption of the Commission decision, the Italian
scheme is in line with EU State aid rules.
In particular, the scheme will contribute to the competitiveness
of the EU maritime transport sector and encourage ship registration
in Europe, while at the same time preserving Europe's high social,
environmental and safety standards and ensuring a level playing
On this basis, the Commission approved the Italian scheme and
its prolongation until 2023 under EU State aid rules.
To address the risk of flagging out and relocation of shipping
companies to low-tax countries outside of the EU, the Commission's
on State aid to maritime transport allow Member States to adopt
measures that improve the fiscal climate for shipping companies.
Only companies that are active in maritime transport (defined as the
transport of goods and persons by sea) are eligible for measures
under the Maritime Guidelines.
The most prominent of such measures is tonnage tax, whereby
shipping companies can apply to be taxed based on a notional profit
or the tonnage they operate, instead of being taxed under the normal
corporate tax system. This can reduce the overall level of taxes
paid and increase their predictability for the companies. Under
seafarer schemes, labour costs (i.e. income tax and social security
contributions) for seafarers employed on board vessels flying the
flag of EU or European Economic Area (EEA) Member State may be
partly or totally reduced.
In its application of the Maritime Guidelines, the Commission is
determined to ensure consistency and equal treatment of shipping
companies throughout the EU whilst at the same time making sure that
any beneficial tonnage tax and seafarer schemes do not contravene
internal market rules. The Commission ensures in particular that
there is no spill-over of the favourable tax treatment of shipping
companies into other sectors unrelated to maritime transport, that
there is no discrimination against other EU or EEA State registries
and that the aid does not exceed the ceiling set out in the Maritime
The Commission's most recent decisions concern the Estonian
tonnage tax and seafarer scheme (Case SA.53469),
the prolongation of the Cyprus tonnage tax and seafarer scheme (Case
the prolongation of the Danish seafarer scheme (Case SA.52069),
and the extension of the Belgian seafarer scheme (Case SA.56475).
The non-confidential version of the decision will be published
under the case numbers SA.48260 in the State
aid register on the Commission's competition
website once any confidentiality issues have been resolved. The
Aid Weekly e-News lists new publications of state aid decisions
on the internet and in the EU Official Journal.
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