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Corporate Taxation in the Global Offshore Shipping Industry

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Corporate Taxation in the Global Offshore Shipping Industry Transportation & Logistics International Tax Corporate taxation in the global offshore shipping industry www.pwc.com/transport Contents Introduction 4 Executive Summary 6 Vessel types related to the oil & gas offshore industry 8 Vessel types related to the offshore wind farm and offshore construction industry 10 Vessel types related to other services provided offshore 12 Other tax incentives for shipping entities 14 Final remark 15 Territory contacts 16 your priorities, our professionalism… …doing great work together Corporate taxation in the global offshore shipping industry 3 Introduction Shipping companies that are part of the offshore value chain need to understand how differences in tax treatments can affect their business in key territories. This paper, Corporate taxation in the global offshore industry, takes a detailed look at how relevant vessels are handled. It is a supplement to our longer report, “Choosing your course - Corporate taxation of the shipping industry around the globe” , which focuses more broadly on how the shipping industry is taxed. Both papers focus on the countries around the world that are most important for the 1 shipping industry. In this paper, we focus specifically on The offshore industry is a good shipping companies that are part of example. Traditional fossil energy the value chain within the offshore extraction, green energy and offshore industry (wind farms, oil rigs etc.). construction have all made significant While offshore activities may be more advances to keep pace with growing commonly seen as part of the energy demand. That’s led to an increased businesses, the shipping industry demand for specialised offshore vessels actually performs a number of critical and for the development of offshore services using highly specialised vessels. support services around the globe. These include wind farm construction There has been a significant increase vessels, accommodation and support in both the number of market players vessels, FPSO’s (Floating Production and in the types and designs of the Storage and offloading vessels), anchor specialised vessels servicing the sector. handling and drill ships. And companies have also developed a wider range of shipping services that are The shipping industry has undergone offered to the offshore industries within significant developments over the last oil & gas, wind farms, and offshore 15 years, since shipping tax regimes construction projects. started to be introduced. In addition, the financial crisis put pressure on But legal frameworks have not always companies to get more efficient, but kept up with this rapid pace of change. that’s not the only way shipping has For example, recent surveys show that changed. The industry has also made more than 18 vessel types are now significant technological advances – being operated during an offshore wind and so have the industries shipping project life cycle — far more than what companies serve. was anticipated when applicable laws The offshore shipping and regulations were drafted for this industry has changed sector. dramatically in recent years, but legal frameworks have not always kept up. 1 We have excluded Russia and Brazil from this analysis because our research shows that these countries do not have special tonnage tax incentives aimed towards the offshore shipping industry. For more information on shipping tax incentives in Russia and Brazil, please see our related report Choosing your course - Corporate taxation of the shipping industry around the globe 4 Corporate taxation in the global offshore shipping industry To stay competitive in the offshore environment, And while a number of countries throughout the world, that act as key companies will centres for shipping services, offer special incentives targeted towards need to look for traditional shipping companies both a competitive operating container, tanker, dry bulk, and passenger vessels, far fewer regulatory provide the same beneficial regimes or incentives to offshore shipping players. framework and high For example, within the EU, the EU quality specialised Commission has sanctioned state aid measures such as tonnage tax and net resources that are salary/salary tax refund schemes, which Socrates Leptos-Bourgi member countries can implement in dedicated to the Global Shipping & Ports their national legislation. Similar tax Coordinator sector. incentives are available in numerous Transportation & Logistics countries in Asia, America etc. But these Leader Greece types of regulations haven’t yet kept up with the increasing specialisation of the offshore shipping industry. Competition in the shipping industry is fierce, and where you locate operations matters. To stay competitive in the offshore environment, companies will need to look for both a competitive regulatory framework and high quality specialised resources that are dedicated to the sector. This report reviews the tax regimes applicable to shipping companies Bo Schou-Jacobsen operating in the offshore sector in a Transportation & Logistics number of key jurisdictions around the Leader Denmark globe. Our comparative analysis can help companies evaluate their options when establishing new services and operations or considering relocation of existing operations. We hope you find it useful reading. Best Regards Lars Koch Vinther Tax Leader Shipping Denmark Corporate taxation in the global offshore shipping industry 5 Executive summary In this report, we provide a condensed overview of the special tax regimes available for shipping companies in certain key jurisdictions around the globe, with a particular view to those that may benefit shipping companies operating in the offshore sector. Shipping companies operating in the offshore niche market are likely to operate specialised offshore service vessels such as AHTS (Anchor Handling Tug Supply vessels), PSV’s (platform supply vessels), FPSO’s (floating production storage and offloading vessels), wind farm construction vessels, drill ships, seismic vessels, crew transfer vessels, tugs etc. There are significant variations in how tax systems treat each vessel and service type. Our analysis covers 17 carefully selected countries around the globe and focuses on the types of vessels most commonly used in the oil and gas offshore industry, the offshore wind farm industry and various other offshore industries. Our research shows that there is a In contrast, countries such as Denmark, broad spectrum of taxation approaches. Ireland, Italy and France take a more Countries such as Singapore and restrictive approach to the applicability Cyprus take a very liberal approach; of their tax regimes to offshore in these countries, various offshore vessels. In these countries vessels are vessels can generally be covered by their required, either by law or by generally beneficial shipping taxation regime. For accepted common practice, to exercise instance, Singapore offers an outright some kind of transportation of goods tax exemption to income (application or passengers. That creates a more required for non-Singapore flagged restrictive environment and impacts vessels) derived from the operation the ability of offshore market players of various vessels outside the limits of situated in these countries to compete the port of Singapore regardless of the over the long term. characteristics of the vessel in question. In some cases the situation differs Countries such as Malta, UK, Germany, by type of vessel. AHTS, PSV’s and Netherlands and Norway take what we tugs can be included in the system in regard as a fairly liberal approach to the Denmark, whilst other vessels such as applicability of their special taxation of drill ships, seismic vessels, and wind shipping activities to offshore vessels. farm installation vessels are specifically These countries have more detailed excluded. That may change, though. requirements that need to be met in The Danish Ministry of Taxation order for offshore activities to benefit recently announced that it intends from their systems. A number of specific to broaden the scope of the Danish vessels/service types may be or probably tonnage tax scheme so that e.g. wind are covered by their advantageous farm construction vessels, support and taxation of shipping income regimes, construction vessels, ice breaking vessels assuming that requirements are met. etc. will be covered as well. No schedule However, a minority of types of vessels for changes has been announced yet, so might not be or are probably not this plan is still in the proposal stage. covered. 6 Corporate taxation in the global offshore shipping industry Key shipping countries’ approach to allowing offshore vessels/services to be covered by their shipping tax incentives. Very liberal approach Fairly liberal approach Fairly restrictive approach Very restrictive approach Singapore Germany Denmark1 Finland Hong Kong UK France USA Cyprus Greece India UAE Norway Italy Netherlands Ireland 1) Please note that the Danish Government has announced to widen the scope of tonnage tax to a number of offshore vessels/ activities, thus wind farm installation vessels, accomodation vessels, security and patrol vessels, Icebreaking and other offshore vessels might be included during 2015 or late 2014. This could potentially move Denmark from a fairly restrictive to a fairly liberal approach depending on how the changes will be implemented and whether or not the changes will also cover seafarer incentives. More detailed information on tax In countries that use tonnage tax and other
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