IMPROVED RULES FOR SWEDISH TONNAGE TAXATION

Tonnage taxation is an elective regime under which qualifying shipping companies compute their taxable income from qualified shipping operations as a fixed amount based on net tonnage, rather than under conventional profit taxation. In force since 2017, the regime has primarily covered traditional freight and passenger transport, with a minimum gross tonnage of 100 for qualifying vessels and a bareboat charter limit of 20% of aggregate gross tonnage, for at most three years during a ten-year period.

The amendments expand the regime in three main respects. First, specialised shipping — including towing, salvage, icebreaking, bunkering, cable- and pipe-laying, sea rescue, environmental remediation, and construction, repair, service and dismantling of offshore installations — is brought within the system through an exhaustive list. Second, the minimum gross tonnage for specialised vessels is lowered to 20. Third, the bareboat charter limit is increased from 20% to 50% of aggregate gross tonnage. In addition, the requirement that a vessel mainly operates in international traffic is replaced by a requirement that it is used in traffic exposed to international competition. The European Commission approved the amended regime under EU state aid rules in May 2026, for the period 2027–2036.

The amendments entered into force on 20 July 2026 and will be applied for the first time on fiscal years beginning after 31 December 2026.