The resource rent tax is designed as a cash flow tax, i. e. revenues and investments are taxed on an ongoing basis in the year they are earned/incurred. The resource rent income shall constitute the difference between an established gross income less deductible costs and any negative resource rent income to be carried forward, less a basic tax-free allowance.
According to the Government, the rules will be designed so that only the larger aquaculture farmers will have to pay the resource rent tax. This will be achieved by introducing a basic tax-free allowance of between 4 000 and 5 000 tonnes biomass. The basic tax-free allowance is considered a stipulated deduction for historical purchases of commercial fish farming licences and is granted at a group level. The basic tax-free allowance is calculated based on an estimate of the average profit per tonne of biomass and can be deducted from any positive resource rent income.
The resource rent tax includes revenues from commercial fish farming licences for the production of salmon, trout and rainbow trout, regardless of how the holder of the licence is organized. Development licences are not covered by the resource rent tax. However, development licences that are converted into commercial fish farming licences will be covered by the resource rent tax from the time of conversion. The resource rent tax shall apply to all licences within the geographical scope of the Norwegian Aquaculture Act, out to the continental shelf.