Following 30 years of involvement with taxation in the shipping industry, we are familiar with most of the tax issues that shipping companies may need to deal with.

Areas where we can add value include:

Structural Issues
Corporate structures can be tax efficient, ensuring no more than single taxation. They can also lead to double taxation or multiple taxation harmful to the business. A review of corporate structures can be advisable whenever there are changes in business operations, mergers and acquisitions or changes in tax regulations.

Through a corporate structure review, we can assist in identifying the optimal structure for your current business model in the current tax landscape.

Freight Tax Issues
Disputes and uncertainties in relation to freight taxes can arise in most parts of the world. There are four main categories of issues.

1. Tax Treaty Interpretation Issues - Scope of shipping exemption
2. Tax Treaty Benefits Entitlement Issues
3. Freight Tax Scope Issues
4. Documentation requirements

Tonnage Tax Issues
There are two main issues in relation to tonnage tax.

1. Qualification challenges concern a shipping company’s fulfilment of the eligibility conditions for tonnage tax. These are mainly related to the substance and location of strategic and commercial management and flagging.
2. Scope challenges concern the activities eligible to be included under tonnage taxation. These disputes are a domestic parallel to the scope of the exemption under tax treaties.

Transfer Pricing Issues
Transfer pricing issues typically relate to agency remuneration or shared service activities.

Experience from close involvement with these issues in many parts of the world and our participation in the Global Shipping Tax Network, of which we are a founder member, means that we can assist you in finding the best approach to find a solution.