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RIVISTA DI DIRITTO TRIBUTARIO INTERNAZIONALE - Rdti.it

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A. S. Bergantino: Tomzage tax: the Italial1 proposal and the European expenences<br />

fact, according to a well-known survey, which has also been widely accepted<br />

by the European Commission, would generate 70% of the total<br />

value added of the sector (14).<br />

Hence the reasons why European govemments have introduced numerous<br />

measures to support the shipping industry: fewer obligations on<br />

seafarers' national<strong>it</strong>y, accelerated depreciation, tax-exempt funds for cap<strong>it</strong>ai<br />

gains deriving from the disposal of fixed assets, reduction of the income<br />

tax rate, partial or total tax exemption of prof<strong>it</strong>s, reduction or elimination<br />

of social secur<strong>it</strong>y payments by ship-owner, graduai reduction, and<br />

in some cases total exernption, of incorne tax obligations on seafarers'<br />

wages, establishment of international registries. More recently, following<br />

the 1997 Commun<strong>it</strong>y document, the "tonnage tax" has been introduced<br />

in numerous European countries.<br />

4. The tonnage tax: a European tax<br />

The tmmage tax, a form of taxation typical of countries that make<br />

open registries available to shipowners, has become in Europe - after the<br />

pioneering experience of Greece - a fiscal measure very appealing to both<br />

operators and governments. For many countries, in fact, <strong>it</strong> has represented<br />

one of the answers to the growing crisis in the sector. Greece introduced<br />

tonnage tax in1938. In 1975 <strong>it</strong> extensively reformed <strong>it</strong>s regime<br />

which is currently under further review. After Greece, The Netherlands<br />

was the first country in Europe to introduce tonnage tax, in 1996. The<br />

example was followed by: Norway (1997), Germany (1999), the Un<strong>it</strong>ed<br />

Kingdom (2000), Ireland (2001), Denmark (2001), Spain (2001) and Finland<br />

(2001). Sweden should only just have introduced the new regime<br />

whereas <strong>it</strong>s approvai is currently being discussed in France and Belgium.<br />

Tonnage tax, as mentioned in the foregoing paragraphs, is a lumpsum<br />

taxation system for incorne from mar<strong>it</strong>ime activ<strong>it</strong>ies. By applying<br />

this system the shipping company - regardless of the actual results of <strong>it</strong>s<br />

activ<strong>it</strong>y - is to pay a tax calculated on the basis of the tonnage of the ships<br />

making up <strong>it</strong>s fleet (15).<br />

(14) A detailed explanation of the estimating procedure ean be found in Poliey<br />

Research Corporation N.V.-ISL (2001) and in Peters C. et al. (1996).<br />

(15) The calculation is normally carried aut by dividing smp size in classes, each<br />

of which has a specific (inversely related to overall size) multiplicative coefficient. In<br />

other \vords, the ship's net register tons (nrt) that belong to each c1ass (divided by 100<br />

or by 1,000 depending on the country) are multiplied by the specific coefficient. The<br />

<strong>RIVISTA</strong> <strong>DI</strong> <strong>DI</strong>RfITO <strong>TRIBUTARIO</strong> INTERKAZIONALE 312001

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