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V3777-15 30 November 2015 · SG de Impuestos sobre las Personas Jurídicas Criterion in force
IS · régimen de tonelaje

Tugboats may qualify for tonnage tax regime subject to income and management requirements

An ocean-going towing services company has enquired whether its vessels can apply the special tax regime for shipping companies. The DGT indicates this is possible provided that less than 50% of income is derived from port activities or assisting vessels in reaching port.

The question raised

Whether the aforementioned vessels are eligible to apply the special regime for shipping companies based on tonnage.

The DGT's ruling

For tugboats to qualify for the tonnage regime, less than 50% of the income for the tax period must derive from activities carried out in ports or from providing assistance to a self-propelled vessel to reach port. Furthermore, they must meet the requirements of strategic and commercial management from Spain or the EU/EEA, and be registered in Spain or the EU/EEA. The entity must submit a new application to include the new vessels.

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