Netherlands Maritime and Shipping Tax Guide

Seafarer Income Tax Exemption (Zeeliedenregeling)

• 0% Dutch income tax on seafarer wages: Under the zeeliedenregeling (seafarer exemption), seagoing personnel employed by a qualifying shipping company can receive their wage income free of Dutch income tax. The exemption applies to: (a) Dutch resident seafarers working on qualifying vessels, and (b) non-resident seafarers working on Dutch-flagged vessels. The employer must withhold the correct amount (0%) and report the wage as exempt in the payroll tax return.
• Qualifying vessels: The exemption applies to vessels used for the transport of goods or passengers by sea (koopvaardijschepen), including dredging vessels, offshore supply vessels, and survey vessels — provided they are engaged in maritime navigation (as opposed to stationary operations). Vessels operating exclusively in inland waterways or ports do not qualify.
• Qualifying seafarers: The exemption covers all crew members (captain, officers, engineers, deck crew, catering staff) working on board the vessel. The seafarer must spend at least 30 days per year working on board a qualifying vessel. The exemption applies to wages attributable to time spent on board (including leave days if the leave is accumulated sea-service leave).
• Social security: The zeeliedenregeling applies only to income tax — social security contributions (AOW, WW, WIA, ZVW) may still be due depending on the flag, the seafarer's residence, and applicable social security agreements (A1 certificate for EU seafarers posted to Dutch-flagged vessels). EU seafarers working on Dutch-flagged vessels generally remain covered by their home country's social security for up to 24 months (A1). Non-EU seafarers on Dutch-flagged vessels are typically covered by the Dutch social security system — the employer pays the premiums.
• Payroll administration: The employer must report the exempt wages in the loonheffingen return under the specific code for seafarer income (code 24 — zeeliedeninkomen). The employer must maintain documentation: the seafarer's employment contract, vessel registration certificate, flag documentation, and records of days at sea.

VAT — Maritime and Port Services

• Port services (havenvergunningen): Services provided within the port area (Port of Rotterdam, Amsterdam, Moerdijk, Vlissingen) may be subject to specific VAT treatment. Port dues (havengelden) paid by vessel owners to the port authority are exempt from VAT as rental of immovable property (verhuur van onroerende zaken). Berth rental is exempt — but stevedoring, pilotage, towage, waste reception, and other operational services are taxable at 21% (unless they relate directly to seagoing vessels).
• Supplies to seagoing vessels — 0% VAT: Supplies (fuel, provisions, spare parts) to qualifying seagoing vessels engaged in international transport are 0% VAT (nultarief) under Article 9(2)(a) of the Wet OB 1968. The 0% rate applies to: bunkering (brandstof), ship chandelling (proviandering), repairs and maintenance, and technical supplies. The vessel must be engaged in international transport (between EU and non-EU ports or between non-EU ports). The supplier must hold documentary evidence (the vessel's IMO number, the shipping company's declaration, and evidence of the international voyage).
• Transfer of cargo to/from ships — 0% VAT: Loading, unloading, and handling of cargo for seagoing vessels engaged in international transport is 0% VAT (nultarief voor laden en lossen). This includes stevedoring, container handling, and terminal services. The cargo must be destined for or arriving from a non-EU country. The terminal operator must retain the shipping documentation (bill of lading, manifest).
• Repairs and maintenance of seagoing vessels — 0% VAT: Repairs, dry-docking, and maintenance of qualifying seagoing vessels are subject to the 0% VAT rate. This is a major competitive advantage for Dutch ship repair yards (e.g., Damen Shipyards, Royal IHC, Rabobank ship finance). The 0% rate applies only to vessels > 2,000 gross tonnage engaged in international transport. Small vessels (under 2,000 GT) or vessels used in inland waterways are subject to 21% VAT on repairs.
• Ship management VAT: Ship management services (crew management, technical management, commercial management) provided to a vessel owner are subject to 21% VAT unless the services relate to a qualifying seagoing vessel and are provided to a non-EU customer (outside scope of Dutch VAT). Management fees for EU-flagged vessels are 21% VAT, which the shipowner may recover if they are a VAT-registered taxable person (most shipping companies are VAT-registered for their 0%/exempt supplies).

Offshore and Dredging

• Offshore supply vessels (OSVs): OSVs are treated as qualifying vessels for tonnage tax purposes if they are engaged in the transport of supplies to offshore installations. The zeeliedenregeling applies to OSV crew. The offshore installation itself (platform, FPSO) is not a qualifying vessel — installation activities (construction, commissioning, decommissioning) are excluded from tonnage tax and taxed at normal corporate rates.
• Dredging (baggeren): Dredging is a qualifying activity under the tonnage tax if the dredging vessel is engaged in maritime transport — i.e., moving dredged material from one port/location to another. Stationary dredging (deepening a port basin without transporting the material) is an excluded activity (normal corporate tax). Companies like Van Oord and Boskalis typically operate a mix of qualifying and non-qualifying vessels.
• Offshore wind: Installation vessels for offshore wind farms may qualify for tonnage tax if they are used for transport (moving personnel, equipment, and materials to and from wind farms). Stationary installation work is excluded. The Dutch government encourages a maritime tax framework for offshore wind supply vessels — see our Renewable Energy Guide (for analogous rules; Danish regime differs).

Maritime Investment and Financing

• Ship finance — interest deduction: Interest on loans for vessel acquisition is deductible under the normal corporate tax rules. For tonnage tax companies, the interest expense is not separately deductible (the tonnage tax profit is deemed to include all operating costs, including financing costs). This means highly leveraged shipping companies may be better off in the normal corporate regime — analysis is required before opting into the tonnage tax.
• Maritime leasing (scheepslease): Dutch shipping companies may use financial lease (financial lease) or operational lease (operational lease) for vessel acquisition. The lease rental is deductible under normal corporate tax rules. For tonnage tax companies, the lease rental is not separately deductible (included in the tonnage tax calculation). Wet lease (vessel with crew) and dry lease (bare-boat charter) have different VAT treatments: wet lease is a VAT-exempt service (crew included), dry lease is a VAT-taxable supply of goods (the vessel) at 21% VAT (unless the vessel is a seagoing vessel used for international transport — 0% rate may apply).
• Maritime investment allowance (MIA/VAMIL): The Netherlands offers MIA (Milieu-investeringsaftrek) and VAMIL (willekeurige afschrijving milieu-investeringen) for environmentally friendly investments, including: ballast water treatment systems, shore-side electricity (cold ironing), LNG propulsion, exhaust gas cleaning systems (scrubbers), and low-emission engines. MIA provides a deduction of up to 45% of the investment cost from taxable profit; VAMIL allows accelerated depreciation (up to 75%). These are not available for tonnage tax companies (since the profit is not based on actual income — the deduction would be meaningless).
• Shipbuilding and R&D: Dutch shipyards (Damen, Royal IHC, B.V. Scheepswerf) investing in R&D for innovative vessel designs (fuel-efficient hulls, autonomous navigation, offshore energy systems) can benefit from the WBSO (R&D tax credit — 40–50% discount on R&D wage costs) and the innovation box (9% tax rate on qualifying IP income). The innovation box is particularly relevant for ship design IP developed in the Netherlands and used worldwide.

For vessel registration and flagging procedures, consult the Dutch Shipping Inspectorate (Inspectie Leefomgeving en Transport — ILT). For corporate tax on non-shipping activities, see our Corporate Tax Guide →. For personal tax and the 30% ruling for expat seafarers, see our 30% Ruling Guide →.