KPMG report: Shipping and offshore tax update (September 2025)

The KPMG member firm in the Netherlands has prepared a report that summarizes certain global tax-related developments that are relevant for companies involved in shipping and related industries.

Read the KPMG report (September 2025) that covers the following developments:

• Sweden is proposing improvements 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 the 2025 Policy Address, Hong Kong’s Chief Executive stated a continuing commitment to foster the development of a commodity trading ecosystem in Hong Kong.
• The UK’s Tonnage Tax (Training Requirement) (Amendment etc.) Regulations 2025 were laid before the House of Commons on September 9, 2025, and will become effective from October 1, 2025. In addition, HMRC issued a manual on multinational and domestic top-up taxes under Pillar Two covering scope, effective tax rate (ETR), and charging rules.
• The UAE’s Ministry of Finance 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).
• Mauritius’ Finance Act 2025 includes provisions for a 15% domestic minimum top-up tax (DMTT). This follows the 2025-2026 budget announcement made in June 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.
• Shipping companies in Anguilla must now conduct real business activities, management, and decision-making on the island to comply with international economic substance standards.
• Brazil is considering whether oil and gas decommissioning activities may 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.