Tax Update Shipping & Offshore - september 2025

Dear reader,

The global shipping and maritime tax landscape is evolving rapidly, with several jurisdictions introducing significant changes aimed at boosting competitiveness, aligning with international standards, and fostering sustainable growth. Recent developments span from Europe to Asia, the Middle East, and Africa, each with unique implications for shipping companies, commodity traders, and multinational groups.

In Sweden, the government is moving forward with major improvements to the tonnage tax system, aiming to make Swedish shipping more competitive and inclusive. Hong Kong is doubling down on its ambition to become a leading commodity trading and shipping hub. The UK is updating its tonnage tax training requirements and providing fresh guidance for shipping on top-up taxes in line with global anti-base erosion rules. Meanwhile, the UAE and Mauritius are refining their tax regimes to attract international business and comply with the latest OECD standards. Greece has introduced a new cruise passenger tax, and Anguilla is tightening its economic substance requirements for shipping companies.

Below, we highlight the most important changes, their reasons, and who will be affected, so you can stay ahead in this dynamic environment.

Please reach out if you have any questions/remarks to your KPMG contact. Within KPMG specialists around the world focus on this specific industry.

Ernst-Jan Bioch

Content

1. Sweden
2. Hong Kong
3. United Kingdom
4. United Arab Emirates
5. Mauritius
6. Greece
7. Anguilla
8. Brazil

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1. Sweden

Improvements to the Tonnage Tax System

Reasons for the Government’s Assessment

With the aim of strengthening the competitiveness of Swedish shipping, improvements should be made to the tonnage tax system to enable more companies and vessels to be included. The proposed improvements include, among other things, expanding the system to cover certain activities within special shipping. 

In addition, certain adaptations and clarifications should be made so that the regulations better align with the EU’s state aid rules.

The Ministry of Finance has circulated the memorandum "Improved Rules for Swedish Tonnage Taxation" for consultation. The government intends to return to parliament with a proposal in the spring of 2026. Before the announced proposal can enter into force, it must be notified to and approved by the European Commission. The forthcoming proposal is intended to enter into force on 20 July 2026 and be applied for the first time for tax years beginning after 31 December 2026.

The forthcoming proposal is estimated to reduce tax revenues by SEK 60 million in 2027 and by SEK 110 million per year from 2028, when the proposal is expected to have full effect.

Here you can find the memorandum referred to above, but to summarize the proposals include, among other things, the following: 

• The Swedish tonnage tax system will be extended to certain activities within special shipping, a collective term for various types of activities such as cable and pipe laying, salvage, icebreaking, and operations related to offshore wind turbines, oil platforms, and similar installations at sea.
• The possibilities to lease out qualified vessels without crew within the framework of tonnage-taxed activities will be expanded.
• Furthermore, it is proposed to introduce some changes to the requirements that a vessel must meet to be considered qualified. For example, the requirement for international voyages will be removed and replaced with a requirement that the vessel is used in traffic exposed to international competition in the shipping market. It is also proposed that a lower gross tonnage requirement should apply to vessels within special shipping.
• The memorandum further proposes to introduce more generous conditions for companies to use a so-called over-depreciation reserve. Some clarifications and adjustments to the current rules are also proposed. This includes, among other things, regulations regarding which related activities are considered qualified shipping activities, with a proposal to specify these exhaustively in the legislation. For companies in financial difficulties, it is proposed that they should not be eligible for tonnage taxation. An adjustment is also proposed to the calculation of the blocking period in the event of withdrawal of approval for tonnage taxation.

2. Hong Kong

Promote commodity trading and shipping indirectly

The Chief Executive has delivered the 2025 Policy Address serving as a roadmap for Hong Kong to strive for, among others, a vibrant economy. Hong Kong states to continue to follow the direction set out in the last Policy Address to foster the development of a commodity trading ecosystem in Hong Kong. Relevant measures include:

1. Support the sector in setting up more approved warehouses, having obtained the approval of the London Metal Exchange, a wholly-owned subsidiary of the HKEX, on the establishment of eight delivery warehouses in Hong Kong.
2. Provide half-rate tax concessions for commodity traders to set up businesses in Hong Kong, driving demand for shipping and professional maritime services. Legislative amendments will be made in the first half of next year.
3. Enhance the process of international commodity trading through financial innovation, including testing the use of technologies like electronic bills of lading and tokenised deposit in a collaboration between the HKMA and Banco Central do Brazil to facilitate trade.
4. Deepen connections with the Guangzhou Futures Exchange and other commodity markets in the Mainland, contributing to the internationalisation of our country's commodity market.

The Government will set up the Strategic Committee on Commodities, led by the Financial Secretary. It will bring together industry representatives with the aim of strengthening the top-down design and long-term strategy of our commodity policy.

3. United Kingdom

Tonnage tax training payments to increase by 20 percent

The Tonnage Tax (Training Requirement) (Amendment etc.) Regulations 2025opens in a new tab were laid before the House of Commons on 9 September 2025 and will come into force from 1 October 2025. The UK Tonnage Tax regime requires the training of officer cadets (see The Tonnage Tax (Training Requirement) Regulations 2000opens in a new tab). If this cannot be achieved it requires payments in lieu of training (PILOTs) to be made. The rate of PILOTs normally increases annually in line with inflation. This year, however, the increases are around 20 percent, which more than makes up for the rate freeze in 2024. The standard monthly PILOT is to increase from £1,421 to £1,705. The ‘basic’ rate used to calculate PILOT based penalties is to increase from £1,329 to £1,613. 

Many global groups are interested in joining UK tonnage tax at present (as the EU/EEA regimes often struggle with flag requirements and sometimes a limited scope of vessels that can benefit from the tonnage tax regimes) and the qualifying UK cadets will be at a premium. This 20 percent rate hike will be an extra cost for such groups if they simply cannot find the cadets to recruit. 

HMRC Issues Manual on Multinational and Domestic Top-Up Taxes Under Pillar Two Covering Scope, ETR and Charging Rules

The UK tax authority, HMRC, has released an internal guide about the multinational top-up tax (MTT) and domestic top-up tax (DTT). This guide goes into detail about how the top-up tax works, including what’s covered by the tax, how the effective tax rate (ETR) is calculated, and how everything is managed.

The Multinational Top-up Tax and Domestic Top-up Tax Manual shares HMRC’s take on different issues related to these taxes. HMRC explains that the MTT puts in place the income inclusion rule and the undertaxed profits rule, which are also known as the Global Anti-Base Erosion (GloBE) rules, as set out in the OECD’s Pillar Two Model Rules. The DTT is the UK’s version of the qualifying domestic minimum top-up tax (QDMTT) and applies the main Pillar Two rules to UK companies.

4. United Arab Emirates

Updated rules for qualifying free zone taxpayers (including shipping)

The Ministry of Finance in August 2025 issued Ministerial Decision No. 229 of 2025, together with Ministerial Decision No. 230 of 2025 (both effective retroactively from June 1, 2023), providing new rules regarding the scope of “qualifying activities” for “qualifying free zone persons” (QFZPs) that may benefit from the 0% corporate tax rate under the QFZP regime (subject to certain conditions).

Ministerial Decision No. 229 of 2025 replaces Ministerial Decision No. 265 of 2023 and provides welcome clarifications for commodity traders.

Read a September 2025 report prepared by the KPMG member firm in the UAE.

5. Mauritius

Finance Act 2025 includes 15% domestic minimum top-up tax (DMTT)

The Finance Act 2025, published in the Official Gazette on August 9, 2025, includes provisions for a 15% domestic minimum top-up tax (DMTT). This follows the 2025-2026 budget announcement made in June 2025 (read TaxNewsFlash).

The DMTT applies to qualifying domestic group members of multinational enterprise (MNE) groups under Pillar Two, starting from the year of assessment commencing on July 1, 2025. The Finance Act aligns with global anti-base erosion (GloBE) rules, excluding cross-border taxes like controlled foreign corporation (CFC) taxes for DMTT purposes. Special provisions apply to investment entities, international shipping income, and joint ventures. The rules also incorporate substance-based income exclusions and safe harbour provisions to ensure fair application.

MNE groups must register with the Mauritius Revenue Authorities and file DMTT returns within specified deadlines, with penalties for non-compliance.

Read an August 2025 report prepared by KPMG’s EU Tax Centre

6. Greece

Cruise passenger tax 

On July 18, 2025, the Greek Ministry of Shipping and Island Policy issued a circular announcing the implementation of a new cruise passenger tax (“cruise fee”) in accordance with Law 5162/2024 and the relevant Joint Ministerial Decision (KYA). The fee applies to all cruise ship passengers disembarking at Greek ports, regardless of age or whether the port is a transit or homeport. Exemptions apply for passengers disembarking for medical reasons and for crew members.

The cruise fee must be declared and paid electronically via a dedicated online platform (e.hcg.gov.gr) by the cruise company, the shipping agent, or the Greek managing company of the cruise ship. The declaration and payment are required per calendar quarter, with specific deadlines for 2025. The circular also provides instructions for the responsible parties on how to use the platform, and mandates random checks by port authorities to ensure proper collection.

Key changes and who is affected:

Key changes:

• Introduction of a mandatory cruise passenger tax for all cruise ship passengers disembarking at Greek ports.
• Payment and declaration must be made electronically through a new online platform.
• The tax is due quarterly, with special deadlines for 2025.
• Exemptions are only for medical disembarkations and crew members.
• Port authorities are required to conduct random checks to ensure compliance.

Who is affected:

• Cruise companies operating in Greece.
• Shipping agents handling cruise ships at Greek ports.
• Greek managing companies of cruise ships.

Passengers on cruise ships disembarking in Greece (except those exempted).

7. Anguilla

Shipping companies in Anguilla must now conduct real business activities, management, and decision-making on the island to comply with international economic substance standards. Failure to do so can result in significant penalties and regulatory action. This follows from Anguilla’s “Guidance on Economic Substance Requirements” which is to explain the rules and expectations for companies registered in Anguilla that are involved in certain business sectors, including shipping. These rules were introduced to comply with international standards set by the OECD and the EU to prevent tax avoidance and ensure that companies claiming Anguilla as their base actually conduct real business activities there.

For the shipping sector specifically:

• The guidance clarifies that shipping businesses must demonstrate “economic substance” in Anguilla if they operate one or more ships in international waters for the transport of passengers or cargo.
• To meet the economic substance test, a shipping company must:
  • Have an adequate number of qualified employees physically present in Anguilla.
  • Incur sufficient operating expenses in Anguilla.
  • Maintain adequate physical assets (such as offices or facilities) in Anguilla.
  • Carry out core income-generating activities (CIGAs) in Anguilla, such as managing crew, maintaining ships, overseeing deliveries, and organizing voyages.
  • Ensure that the “mind and management” (i.e., key decision-making) for the shipping business is located in Anguilla.
• Key changes:
  • Shipping companies registered in Anguilla must now prove they have real operations and management in Anguilla, not just a legal address.
  • Outsourcing of core shipping activities is only allowed if the work is done in Anguilla and properly supervised by the company.
  • Companies must file annual economic substance returns and provide evidence of their activities.
  • Companies that cannot prove adequate substance may face penalties, information exchange with foreign tax authorities, or even removal from the company register.
  • Exemptions are possible only if the company can prove it is tax resident in another jurisdiction with a corporate tax rate of at least 10%.
• Who is affected:
  • All shipping companies incorporated or registered in Anguilla that operate ships in international traffic.
  • Directors, officers, and registered agents responsible for compliance and reporting.

Foreign companies with shipping operations in Anguilla, unless they qualify for exemption based on foreign tax residence.

8. Brazil

Rumors regarding Repetro-Sped

Question in practice is whether decommissioning activities in Brazil’s oil and gas sector should be covered by the Repetro-Sped special customs and tax regime. Decommissioning, which includes for example well abandonment, dismantling of facilities, and environmental remediation, is becoming increasingly important as many oil fields in Brazil mature. 

The Repetro-Sped regime currently provides tax benefits for goods used in exploration, development, and production, but it is unclear if decommissioning qualifies as part of "production" under existing laws. While the law does not explicitly mention decommissioning, related regulations and contracts treat it as part of the production cycle. The discussion is ongoing about whether goods used in decommissioning should receive the same tax treatment as those used in earlier stages of oil and gas operations. Keep you posted! 

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