Offshore Wind & het tonnageregime. Sander Wortelboer Suzanne Wieringa

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1 Offshore Wind & het tonnageregime Sander Wortelboer Suzanne Wieringa November 2012

2 Inhoud Doel: Informeren belanghebbenden over toepassing tonnageregime in de offshore wind industrie Kader: Winstregime (IB / Vpb) Tonnageregime Normaal winstregime Overige fiscale faciliteiten LB BTW

3 Application Tonnage Tax Regime Liable to tax in The Netherlands Profits from ocean shipping Timely request and formal decision TA and and and Period: 10 years or multiple Operation of sea-going vessels and Directly related activities Transport of people or goods or Dredging, mainly transportati on or Tow-/ assistance to vessels (harbour excluded) Exploration of the seabed (research vessels) Cable or pipe laying on the seabed or or or Lifting at sea (crane vessels) For the international transportation or Exploration/ exploitation natural resources

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5 Application Tonnage Tax Regime Liable to tax in The Netherlands Profits from ocean shipping Timely request and formal decision TA and and and Period: 10 years or multiple Operation of sea-going vessels and Directly related activities Transport of people or goods or Dredging, mainly transportati on or Tow-/ assistance to vessels (harbour excluded) Exploration of the seabed (research vessels) Cable or pipe laying on the seabed or or or Lifting at sea (crane vessels) For the international transportation or Exploration/ exploitation natural resources

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11 Application Tonnage Tax Regime: conditions (2) Operation of sea-going vessels Time- and voyagecharter 70% Commercial management for others ór ór ór Shipmanagement Ownership / bareboat-in ánd 5% From The Netherlands Complete technical- and crewingmgt + ISM responsible EU / EER Flag, unless exceptions 30% management from The Netherlands Strategic management (ownership) Commercial management (bareboat-in) In 2012 EU / EER Flag is not required In 2013 it is required

12 Application Tonnage Tax Regime: conditions (3) Activities directly related to the operation of vessels Profit from the sale of goods, used for the operation of sea-going vessels (Un)loading on own account Ship Broker ( cargadoor ) activities on own account Etc. NB in principle no: - interestrevenues on non working capital - commissions for buildingsupervision

13 Calculation fixed profit from ocean shipping ( ) Profit per vessel ( )* Fixed profit per day ( ) Days in operation Net tonnage Amount according to table ( ) per vessel (rounded down to thousands) NT = 9,08 per NT NT = 6,81 per NT NT = 4,54 per NT NT = 2,27 per NT > NT = 0,50 per NT *in case of shipmanagement the profit will be reduced with 75%

14 Calculation profit from ocean shipping ( ) Commerciële winst volgens jaarrekening: Berekening winst o.b.v. het tonnageregime Netto tonnage NT Tonnagewinst per dag 36,32 Aantal vaardagen 365 Winst uit zeescheepvaart per jaar Vpb last (25,0%) Belastingdruk 0,44%

15 In the Netherlands, Deloitte is the member firm of Deloitte Touche Tohmatsu, and services are provided by Deloitte and its subsidiaries. Deloitte is among the Netherlands' leading professional services firms, providing audit, tax, consulting, and financial advisory services through nearly 7000 people. Known as an employer of choice for innovative human resources programs, it is dedicated to helping its clients and its people excel. For more information, please visit the Netherlands member firm s website at Deloitte Touche Tohmatsu is a Swiss Verein (association), and, as such, neither Deloitte Touche Tohmatsu nor any of its member firms has any liability for each other's acts or omissions. Each member firm is a separate and independent legal entity operating under the names "Deloitte," "Deloitte & Touche," "Deloitte Touche Tohmatsu," or other, related names. The services described herein are provided by the member firms and not by the Deloitte Touche Tohmatsu Verein.