Netherlands Fisheries and Aquaculture Tax Guide
Dutch fisheries and aquaculture taxation — the Netherlands is the EU's second-largest fisheries producer (after Spain), with major fishing ports at Urk, Den Helder, IJmuiden, and Vlissingen. The fishing fleet includes: kottervisserij (beam trawlers — the largest segment), flyshootvisserij (fly-shoot vessels), and pelagische visserij (pelagic freezer trawlers for herring, mackerel). Aquaculture (aquacultuur) — primarily mussel farming (mosselkweek — Zeeland), oyster farming (oesterkweek), and fish farming (viskweek — eel, tilapia, turbot in recirculation systems). Key tax rules: fishing vessels (visserijschepen) qualify for willekeurige afschrijving (accelerated depreciation — 100% in the first year under certain conditions for new vessels). Fishing quota (vangstrechten) — the permanent quota rights (the visserijvergunning with quota allocation) are intangible assets that are amortisable over their useful life (typically 10–15 years). The quota rights purchased from other fishermen (de aankoop van vangstrechten) can be capitalised and amortised. The visafslag (fish auction) — the sale of fresh fish at the auction is subject to 9% btw (the verlaagd btw-tarief voor levensmiddelen — the reduced VAT rate for food). The fuel tax exemption (accijnsvrijstelling) — gas oil (rode diesel — red diesel for fishing vessels) is exempt from excise duties (accijnsen) under EU Directive 2003/96/EC — the exemption applies to gas oil used as fuel for fishing vessels in EU waters. The exemption reduces the operating cost significantly (diesel is a major cost for fishing vessels). The EU fisheries subsidies (EMFAF) — subsidies for vessel modernisation, fishing gear innovation, and aquaculture investment are generally tax-free for the recipient (the subsidie is not included in the taxable profit if it is a capital grant — the investeringssubsidie is deducted from the asset cost, reducing the depreciation base). The aquaculture tax treatment: fish farming is treated as an agricultural business (landbouwbedrijf) — the landbouwvrijstelling (the agricultural exemption) applies to gains on the sale of agricultural land used for aquaculture, provided the land is used for fish farming (the visteelt). The mussel and oyster farming in the Oosterschelde (the Zeeland delta) is treated as agricultural business — the mosselspecialisten (mussel farmers) are subject to the same agricultural tax rules as land-based farmers.
Fishing Vessel Depreciation
- Willekeurige afschrijving voor vissersschepen: Fishing vessels qualify for accelerated depreciation (willekeurige afschrijving) — the investment in a new fishing vessel can be depreciated by up to 100% in the first year. The accelerated depreciation applies to both the casco (hull) and the vistuig (fishing gear). The benefit: the company pays less corporate tax in the early years of the vessel's life. The accelerated depreciation is subject to the MIA/Vamil regime (if the vessel has environmental technology — fuel-efficient engines, selective fishing gear) or the general willekeurige afschrijving for fishing vessels (Article 3.31 Wet IB 2001). The vessel must be registered in the Nederlands Scheepsregister (the Dutch Ship Register) and must fly the Dutch flag.
Fishing Quota — Vangstrechten
- Quota as intangible assets: Fishing quota (vangstrechten) — the right to catch a specific quantity of a fish species (e.g., 100 tonnes of sole, 500 tonnes of plaice) — are intangible assets under the Dutch tax law. The quota can be acquired by: (a) purchasing quota from another fisherman (the overdracht van vangstrechten), (b) being allocated quota by the government (the Producenten Organisatie — PO — the Producer Organisation allocation), or (c) leasing quota (the verhuur van vangstrechten). Purchased quota is capitalised at the purchase price and amortised over the expected useful life (typically 10–15 years). The amortisation is deductible for Vpb purposes. Leased quota payments are deductible as operating expenses.
Fuel Tax Exemption
- Rode diesel — excise duty exemption: Gas oil used as fuel for fishing vessels (also called rode diesel — red diesel coloured for identification) is exempt from excise duties (accijnzen). The exemption applies under EU Directive 2003/96/EC (Article 15) and is implemented in Dutch law via the Wet op de accijns. The exemption reduces the fuel cost by approximately €0.30–0.40 per litre (the excise duty on regular diesel is ~€0.50/litre — the fishing exemption reduces this to a minimal rate). The exemption applies to gas oil used for propulsion of fishing vessels in EU waters. The vessel must be a recognised fishing vessel with a valid visserijvergunning (fishing licence).
Aquaculture Tax Treatment
- Landbouwvrijstelling for aquaculture: Fish farming (viskweek), mussel farming (mosselkweek), and oyster farming (oesterkweek) are treated as agricultural businesses (landbouwbedrijven). The landbouwvrijstelling (agricultural exemption) applies to gains on the sale of agricultural land used for aquaculture — the gain is exempt from income tax and corporate tax if the land is used exclusively for aquaculture (the vrijstelling voor landbouwgrond — the exemption for agricultural land). The exemption applies to: (a) the sale of land used for fish ponds (visvijvers), (b) the sale of intertidal land (droogvallende gronden — mussel and oyster beds in the Waddenzee and Oosterschelde), and (c) the sale of shellfish farming plots (percelen voor schelpdierenteelt). The empresa (the farming enterprise) is subject to the ordinary business rules for Vpb and IB.
For the agricultural exemption (landbouwvrijstelling) and the agricultural tax rules, see our Agriculture and Farming Guide →. For the excise duty exemption for fishing vessels (the accijnsvrijstelling for minersale olie), see our Excise Duties Guide →. For the marine shipping tax and the tonnage tax regime for fishing vessels (if the vessel elects the tonnage tax), see our Maritime Shipping Tax Guide →. For the reduced 9% btw rate on fresh fish products (the verlaagd tarief voor levensmiddelen), see our VAT/BTW Guide →.