Offshore Wind & het tonnageregime Sander Wortelboer Suzanne Wieringa November 2012
Inhoud Doel: Informeren belanghebbenden over toepassing tonnageregime in de offshore wind industrie Kader: Winstregime (IB / Vpb) Tonnageregime Normaal winstregime Overige fiscale faciliteiten LB BTW
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
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
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
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
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) 1.000 NT = 9,08 per 1.000 NT 1.001 10.000 NT = 6,81 per 1.000 NT 10.001 25.000 NT = 4,54 per 1.000 NT 25.001 50.000 NT = 2,27 per 1.000 NT > 50.000 NT = 0,50 per 1.000 NT *in case of shipmanagement the profit will be reduced with 75%
Calculation profit from ocean shipping ( ) Commerciële winst volgens jaarrekening: 750.000 Berekening winst o.b.v. het tonnageregime Netto tonnage 5.284 NT Tonnagewinst per dag 36,32 Aantal vaardagen 365 Winst uit zeescheepvaart per jaar 13.256 Vpb last (25,0%) 3.314 Belastingdruk 0,44%
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