Norway proposes CO2-tax cut for offshore ETS vessels from 2027

Bunker fuel suppliers, registered excise businesses and operators of quota-covered vessels face a wider reduced CO2-avgiftSkatteetaten from 1 January 2027Skatteetaten under a proposal from Skattedirektoratet on behalf of FinansdepartementetSkatteetaten. Mineralolje, naturgass and LPG for offshore vessels of 5,000 bruttotonn or more in domestic quota-covered shipping between two Norwegian ports, including legs via installations on the Norwegian shelf, would qualify for the reduced rateSkatteetaten now reserved for domestic quota-covered shipping, and quota-covered voyages from a Norwegian port to a foreign port via such installations would be exempt from the taxSkatteetaten.

Since 1 January 2024, emissions from vessels of 5,000 bruttotonn or more carrying passengers or cargo for commercial purposes have been part of the EU emissions trading systemSkatteetatenSkatteetaten. To avoid a higher combined emissions price than other sectors under the effort-sharing rules, Norway introduced a reduced CO2-avgift rate for domestic quota-covered shippingSkatteetaten. After clarification with EFTA Surveillance Authority ESA on state-aid compatibility, the reduced rate took effect on 1 March 2026Skatteetaten, with a refund of the difference between paid tax and the reduced rate for 1 January to 28 February 2026Skatteetaten under særavgiftsforskriften § 4-3-1.

The quota obligation expands from 1 January 2027 to offshore vessels over 5,000 bruttotonn sailing to, from or staying in an EEA port of callSkatteetaten under klimakvoteforskriften § 1-5. The current rule defines innenriks sjøfart as fart i norsk territorialfarvannSkatteetaten, so an offshore vessel bunkering in Norway and sailing to an installation on the continental shelf outside territorial waters falls outside the reduced rateSkatteetaten, and because it does not sail directly to a foreign port or a fixed installation outside the Norwegian economic zoneSkatteetaten it also falls outside the general exemption for utenriks fart in særavgiftsforskriften § 4-4-1Skatteetaten.

The proposal replaces the territorial-waters test with fart mellom to norske havnerSkatteetaten. Fuel for quota-covered shipping between two Norwegian ports, including legs via installations, facilities and similar structures inside the Norwegian economic zone, would carry the reduced rateSkatteetaten. Fuel for a quota-covered vessel sailing from a Norwegian port to a foreign port via such installations, which falls outside innsatsfordelingsforordningenSkatteetaten, would be fully exempt from CO2-avgiftSkatteetaten under the principle that quota-covered emissions outside that regulation are exempt under the Storting's tax resolution. The existing direct-exemption model continues: the registered business delivers fuel at the reduced rate or without tax only when the person responsible for bunkering on board or the rederi declares that the fuel is for qualifying useSkatteetaten, identifying the vessel, its nationality and registration, the ship operator under klimakvoteloven § 2a, the quantity and the bunkering dateSkatteetaten.

A rederi may give a general declaration for vessels used exclusively in qualifying traffic, valid for up to one yearSkatteetaten, and the registered business must keep each declaration for ten yearsSkatteetaten. Skattekontoret may require a copy of the deck log or equivalent as proof that the conditions were met. Fuel bought from a non-registered supplier is handled by refund of the difference or of the full taxSkatteetaten. The regulatory amendments would enter into force on 1 January 2027Skatteetaten, the same date offshore vessels become quota-coveredSkatteetaten. Comments may be sent to horingsinnspill@skatteetaten.no by 3 December 2026Skatteetaten with reference 2026/2885Skatteetaten. Legal basis is forskrift 11. desember 2001 nr. 1451 om særavgifter §§ 4-3-1, 4-3-2 and 4-4-1, klimakvoteforskriften § 1-5 and lov 19. juni 2026 nr. 41 om særavgifter §§ 12-1, 12-3 and 12-4.