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Before the end 2006 the Netherlands Antilles government has amended the tonnage tax legislation
to make the Netherlands Antilles even more attractive for the establishment of shipping business.
A great advantage of the Antillean Tonnage tax, the very broad definition of the taxable profits,
is even further expanded. In principle 'every legitimate use of a vessel'
(outside the territorial
waters of the Netherlands Antilles) is eligible for the Tonnage Tax. Thus specialized ships like
Survey-, fishing-, cable-laying- and dredging vessels, tugboats, (oil-)rigs etc. all qualify for
tonnage-based taxation.
Furthermore vessels are admissible irrespective which flag they fly. The
Antillean company may pay out dividends to shareholders anywhere in the world free of any
withholding tax. In most countries these dividends will, based on the participation exemption
and/or Tax-treaties, be exempt from further taxation. Dividends may be re-invested outside
of the Netherlands Antilles absolutely free of Antillean tax.
Who can apply for the new tonnage tax?
All companies which derive profits from the operation of sea going vessels in international
waters can apply, provided the place of effective management of the enterprise is situated
in the Netherlands Antilles.
Admissible are all vessels which the company:
- owns or co-owns (including ships chartered out on a bareboat charter basis);
- holds under a bareboat charter;
- manages on behalf of a third party; or
- operates in time or voyage charter.
The new tonnage tax method
The new tonnage tax method allows shipping companies to calculate their profits on the
basis of a specified notional profit depending on the net tonnage of the ship. The annual
notional taxable profit per vessel should be calculated on the basis of the following sliding scale.
Net tonnage of vessel Fixed taxable profit per net ton
0 - 10,000 ANG 2.00 (approx. USD 1.12)
10,000 - 25,000 ANG 1,35 (approx. USD 0.76)
25,000 or more ANG 0,60 (approx. USD 0.34)
If a company manages vessels on behalf of third parties, the fixed taxable profit per
net ton should amount to 1/10th of the amounts mentioned above. The standard profit tax
rate of 34.5% should be applied to the resulting notional taxable profit. The minimum
tax liability amounts to USD 562 (USD 281 for management companies).
Example:
A vessel with a Net tonnage of 15,000 owned or chartered by a company will be taxed
USD 5,175,- (= 34.5% of 10,000 x 1.12 + 5,000 x 0.76). The same vessel managed by a
company for a third party will be taxed USD 517.50.
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