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cesso Operators strongly opposed this aspect, considered to be overly penalising
(28).
e) Tenns for opting into the regime
Countries that have adopted the system of lump-sum deterrnination
of the taxable basis have set down terrns for exercising the option: a
year in the United Kingdom and in the Netherlands and three years in
Gerrnany (for ships already enrolled in the national register). In Norway
there is no obligation, as in Greece where, however, the system is
compulsory.
o The period of irrevocability of the option
The Italian proposal requires that the election to the regime is irrevocable
for "a minimum period of five years". All European countries that
have introduced tonnage tax have a similar provision, with the exception
of Greece, on the account of its compulsoriness, and Norway. The election
period is generally of ten years. Also Spain, the latest country to introduce
tonnage tax, has adopted the ten year limi t.
g) Ancillary and related activities
The definition of the ancillary and related maritime transport activities
qualifying for the lump-sum taxation regime is indeed a delicate
aspect, laden with implications in terrns of overall effectiveness of the
measure.
As we have seen, the Bill provides that the new regime "might also"
include income " ... from complementary or ancillary commerciai activities".
This choice is in line with what already done in other countries
which preceded Italy in the introduction of the tonnage tax. The Netherlands,
the United Kingdom and Gerrnany have included, though to a different
extent and with varying degrees of flexibility, income from management
activities, leasing, loading and unloading of cargo, catering and
auxiliary services. Norrnally, their inclusion is made conditional upon the
fact that the activities are actually complementary to the main activity
(which must remain mariti me transport) and, that the provision of services
be mainly on ships that make up the shipowner's fleet.
In the Netherlands and in the United Kingdom, as earlier mentioned,
an objective criteria to identify the extent to which complementary and
ancillary activities can be carri ed out on not owned tonnage has been in-
(28) Though this be the case. the "all in all out" provision seerns to appeal to other
countries which have onI)' just introduced tonnage tax, see for instance Spain.
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