CO2 tax on commercial fishing, ferry operation and aviation
In future, everybody who buys fuel will get an invoice stating the new CO2 tax. You may claim part of the CO2 tax until 2029. But the full CO2 tax will be payable by all from 2030.
The CO2 tax will be introduced gradually prior to 2029.
| Year | Refund, fractons | Refund, percentage |
|---|---|---|
| 2025 | 400/750 | 53.33% |
| 2026 | 320/750 | 42.67% |
| 2027 | 240/750 | 32.00% |
| 2028 | 160/750 | 21.33% |
| 2029 | 80/750 | 10.67% |
| 2030+ | 0/750 | 0% |
This means that in 2025, for example, your refund will be 53.33% of the CO2 tax stated in your invoice.
Different rules apply if you are registered for VAT or not
As a business subject to VAT, you have to use the fields for refund avaiable in your VAT return. If, for example, you want a refund of the CO2 tax, you have to write the actual refund (the amount) in the field CO2-afgift (CO2 tax) in your VAT return.
This means that refund filing deadlines are the same as your normal VAT filing deadlines.
As a business, you're responsible for calculating and stating the correct amount to be refunded.
Authorised exemption
The existing authorised exemption from energy taxes, NOx tax and sulphur tax will continue.
The CO2 tax will not be included in the exemption from 1 January 2025.
This means that everybody who has already been granted an authorised tax exemption when buying fuel will need to contact the Tax Agency to get a new exemption. This is exepcted to take place in early 2025.
The new exemption will apply retroactively from 1 January 2025 and that's the reason that suppliers of oil may supply marine diesel exclusive of certain taxes including energy, Nox and suplhur as previous, but inclusive CO2 tax to fishing vessels that had an authorised exemption before 1 January 2025.
If you don't have a CVR number or a VAT (SE) number as a non-Danish business, you have to register your business first.
You do so via form 40.112 – Registration of non-Danish Company.
In field 14, you state that the reason for your registration is that your business needs a VAT number to apply for an authorised exemption.
When you have a CVR or VAT number, you complete and submit an exemption form to be refunded for your CO2 tax. You do so via form 23.024 - Authorisation for tax exeptions and/or tax refunds on fuel for commercial fishing, domestic ferry operations and domestic aviation.
When you have been granted exemption, you can apply for reimbursement via form 23.004 Request for refund of tax on commercial fuel for commercial shipping, domestic ferry operation and domestic aviation.
The Tax Agency will process your form once you submit it.
All fishing vessels are included in the CO2 tax on fuel
All fishing vessels are subject to the CO2 tax on fuel
The CO2 tax on commercial fishing applies to both international an domestic commercial fishing. As an oil company you always have to include the CO2 tax in the invoice on supply to fishing vessels when you supply fuel within Denmark - or territorial waters within 12 nautical miles from the Danish coastline.
This means that the CO2 tax should always be included on supply of fuel to non-Danish fishing vessels when the fuel is supplied in Denmark.
CO2 tax rates
The new CO2 tax rates on fuel are stated in the CO2 Tax Act at skm.dk: CO2-afgiftsloven (currently in Danish).
As an oil supplier you have to charge the fishing vessels based on the current CO2 tax for the year which is stated in the above act. Also, the CO2 tax must be specified in the invoice from the oil supplier to the fishing vessel.
Please read more in Danish here:
The new rules on reimbursement of energy taxes and the CO2 tax are stated in Act no. 683 of 11 June 2024 and in Bill no. 23 – in the part on adjusting the the completion of agreement on Green Tax Reform for the industry etc.
You find the most recent versions of the acts at skm.dk/skattelove. And you find our legal guide in Danish at skat.dk/juridiskvejledning.
Please find the bill at ft.dk under Dokumenter (Documents)> Lovforslag (Bills) > L 23.