CO2 tax on commercial fishing and domestic ferry and aviation operation
Domestic ferry and aviation operation
From 1 January 2025, the CO2 tax will be stated on the invoice when you buy fuel.
You may claim a partial refund of th CO2 tax in the period 2025-2029. But from 2030, you will have to pay the full CO2 tax.
Payment of the CO2 tax is introduced gradually prior to 2030. In the period 2025-2029 you may claim a partial refund of the CO2 tax stated on your invoice. From 2030, you will have to pay the full CO2 tax.
| Year | Refund, fractions | 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.
Special rules for commercial fishing
On 1 January 2025, a CO2 tax was imposed on fuel for commercial fishing vessels. The tax will be introduced gradually pior to 2030.
Then on 1 January 2026, the CO2 tax on commercial fishing was suspended for the period 2026-2028. The CO2 tax will be reintroduced from 2029.
The CO2 tax will be stated on the invoice for fuel supplied in 2025. You may get a refund of 53.33% of the CO2 tax.
Compnsation for OC2 tax paid in 2025: Contact the Danish Agricultural and Fisheries Agency
As part of the new political agreement 'A new course for Danish fishery' it has been settled that commercial fishing operators can request full compensation for the the CO2 tax paid in 2025. The compensation is made through a scheme managed by the Agricultural and Fisheries Agency.
As a result, you can get a refund of 53.33% of the CO2 tax (via your VAT return or form 23.004) and apply for compensation for the remaining 46.67% with the Agricultural and Fisheries Agency.
Please contact the Agricultural and Fisheries Agency to apply for a compensation of the 46.67%.
You can call the Agricultural and Fisheries Agency for guidance on (+45) 72 18 58 49.
Or you can send the Agency an email at tilskud@lfst.dk.
On 1 January 2026, the payment of CO2 tax on commercial fishing was suspended.
This means that fishing vessels of more than 5 gross ton (GT)/gross register ton (GRT) that are authorised for a tax exemption on fuel may buy fuel withouth having to pay the CO2 tax.
There is no requirement on a seperate authorisation for tax exemtion on the CO2 tax. So, fishing vessels over 5 GT/BRT that are already authorised for exemption on energy, NOX and sulphur tax may also be exempt for the CO2 tax in the period 2026-2028 even if it's not specifically stated in the authorisation.
Fishing vessels under 5 GT/GRT will continue to see invoices stating the CO2 tax and in the period 2026-2028 they will be granted full refund of the CO2 tax on fuel used for commercial finshing via the VAT return or form 23.004.
From 1 January 2029, the CO2 tax will again be stated on all invoices for supply of fuel to fishing vessels.
in 2029, you may request a refund of 50% of the CO2 tax stated on your invoice.
As of 2030, the CO2 tax will be fully introduced and a refund will no longer be available.
Oil suppliers: How do I invoice my customers?
All fishing vessels are subject to CO2 duty on fuel
On 1 January 2025, a CO2 tax was imposed on commercial fishing. Later on, on 1 January 2026, the CO2 tax was temporarily suspended in the period 2026-2028.
The CO2 tax for fishing applies to both domestic and non-Danish fishing when the fuel is supplied within the Danish land or sea territory (within the Danish 12 nautical miles limit). This means that the supply of fuel for both Danish and non-Danish fishing vessels is subejct to the rules as the supply takes place in Denmark.
Invoicing in 2025
In 2025, Oil suppliers were required to state the CO2 tax on the invoice when they supplied fuel for fishng vessels in Denmark.
Invoicing in 2026-2028
The CO2 tax on commercial fishing is suspened in the period 2026-2028 and as a result oil suppliers may supply fuel exclusie of the CO2 tax to fishing vessels over 5 GT/GRT as long as the vessels are authorised to receive tax exempt fuel.
Oil suppliers still have to invoice CO2 tax on supply of fuel to fishing vessels under 5 GT/GRT.
Invoicing from 2029
From 2029, oil suppliers have to state the CO2 tax on th einvoice when fuel is supplied to fishing vessels in Denmark.
CO2 tax rates
The current CO2 tax rates on fuel are set out on skm.dk in the CO2-afgiftsloven (Act on CO2 tax).
Exemption from energy tax, NOx tax and sulphur tax
Oil suppliers may continue to supply fuel to fishing vessels over 5 GT/GRT without charging energy ax, NOx tax or sulphur tax.
In the period 2026-2028, oil suppliers may also decide not to charge the CO2 tax.
Conditions for delivery of tax exempt fuel
A number of conditions must be met in order for fuel to be delivered to fishing vessels free of taxes.
Including the fact that the fuel must be dyed, the fuel must be delivered directly into the vessel’s propulsion tank and the fishing vessel must be authorised to receive tax-free fuel.
If these conditions are met, fuel may be supplied tax-free when fishing vessels refuel themselves from a self-service facility directly into the propulsion tank. It's not a requirement that the oil supplier is physically present during refueling.
A self-service facility is defined as being unmanned. The vessel typically has a card for the self-service facility, which is used during refueling.
Exemption authorisations
Fishing vessels of more than 5 GT/GRT must be authorised to be supplied fuel exempt of energy tax, NOx tax ad sulphur tax.
Fishing vessels may requst an exemption authorisation via form 23.024 Authorisation for tax exemptions and/or tax refunds on fuel for commercial fishing, domestic ferry operations and domestic aviation.
It's stated on authorisaitons issued during 2025, that the tax exemption per 1 January 2025 doesn't include the CO2 tax.
The temporary suspension of CO2 tax for fishing in the period 2026-2028 means that fishing vessels of more than 5 GT/GRT can be supplied fuel without being charged the CO2 tax on the invoice in this period.
Fishing vessels don't need a new authorisation to obtain the temporary suspension from the CO2 tax in the period 2026-2028.
Fishing vessels over 45 GT/GRT that are authorised not to pay energy tax, NOx tax ad sulphur tax may then also be supplied fuel exempt of CO2 tax in the period 2026-2028 even if it's not specifically stated in the authorisation.
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 available 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.
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 exceptions 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.
Please read more in Danish here:
Our legal guide section E.A.4.6.1.7 Calculation of reimbursement (Opgørelse af godtgørelse) - info.skat.dk. Section Partial refund of CO2 tax in the period 2025-2029 (”Delvis godtgørelse af CO2-afgift i perioden 2025-2029").
The new rules on reimbursement of energy taxes and the CO2 tax are stated in Act no. 683 of 11 June 2024 and in Act no. 1489 o f10 December 2024.
NOx tax: E.A.7.2.0.8 Afgiftsfritagelse og afgiftsgodtgørelse
Sulphur tax: E.A.7.11.8.1 Afgiftsfritagelse
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.