Resource rent tax on aquaculture

The new tax regime applies to the farming of salmon, trout, and rainbow trout.

Background

The Norwegian aquaculture business utilizes fjords and sea areas. The number of licenses is limited due to i.e. sustainability, access to land/sea, and different forms of regulations.

The aquaculture business in Norway has achieved extraordinary profits in recent years.

The purpose of the new legislation is to impose an extra tax on profits arising from the sea phase of the fish farming process. The effective tax rate is 25 %. A standard deduction of 70 million Norwegian kroner does, however, apply. The tax is structured as a cash-flow tax, and there is an immediate deduction for costs and investments related to the sea phase. The resource rent tax is charged in addition to the standard corporate tax. The tax applies to ordinary commercial licenses.

The affected municipalities and the state share the proceeds from the new tax.

The Price Council on Aquaculture

The new tax requires that the revenues must be based on the market price at the stage of the production process where the fish leaves the pen.

A challenge with the new tax is that sale of fish to a third party directly from the pen rarely occurs. Several companies in the business have integrated other value-adding services like well-boats, slaughterhouses, packing, filleting, etc. These services do not relate to the growth phase in the sea.

Due to this, it has been decided that an independent Price Council (prisradet.no) shall set the fish price. The Price Council's task is to set the market price when the fish is removed from the pen, in accordance with the arm's length principle. Fish farming companies must thus report every month. 

The Price Council cannot be instructed and the price set by the council is binding. The price settlement decisions can be appealed to the Directorate of Fisheries.

To assist the Price Council the Directorate of Fisheries has established a secretariat.