The draft bill under consultation on ship taxation introduces one of the most extensive overhauls of the institutional framework of Law 27/1975, with immediate impact on shipowners, management companies, yachting professionals, and maritime activity stakeholders. Significant changes to Articles 198, 199, 200, and 202 will take effect from the 2024 tax year, while the regulation for the taxation of ships under foreign flags (Article 201) has already been applied since 2023, reinforcing the need for compliance among managers operating in Greece.

Key Pillar: Second-Class Ships
The central feature of the new framework is the reform of the method for calculating the tax for second-class ships (Article 198). The bill introduces a new scale based on gross tonnage (GRT), establishes a minimum tax, extensively restructures the coefficients by ship category, and differentiates between professional and private recreational vessels, tourist day cruise ships, high-speed boats, tugs, research vessels, fishing boats, and special-purpose ships. Specific reductions are provided for cargo and passenger ships, while the exemption for inactive private recreational vessels is eliminated.

Article 199 – Tax Declaration Requirement
Only ships with a true zero tax coefficient are exempt from the obligation to file a declaration, clarifying a previously ambiguous area.

Article 200 – Transfer and Mortgage Procedures
Significant changes are introduced for ship transfers or mortgages: any registration in the ship registry now requires full settlement of all relevant taxes (tax and contribution under Law 27/1975, crew remuneration tax, fee under Article 57 of Law 4646/2019). Rules for the new shipowner are also strengthened, with tax obligations automatically transferred from the day of transfer.

Article 201 – Taxation of Foreign-Flagged Ships
The bill enhances the taxation mechanism for ships under foreign flags, aligning the declaration and tax payment process with that for Greek-flagged vessels. Tax paid abroad may be credited under strict conditions, and the method of assessment is defined when management is transferred during the year to a Greek company.

Article 202 – Limitation of Exemptions and Reductions
Exemptions and reductions under Article 13 of Law 27/1975 will no longer apply to:

• Private recreational vessels
• Professional recreational vessels
• Tourist day cruise ships
• All types of recreational small craft

The only exception is the special exemption for second-class ships, which remains in force.

Overall Impact of the Bill
The legislation aims to modernize the ship taxation system, address old gaps, reduce ambiguities, and align the tax base with the current needs of maritime activities and the recreational market.

Key points include:

• Expansion of the tax base in the recreational sector
• Elimination of historical exemptions that applied to much of the sector
• New requirements for charter companies, tourist day cruise operators, and private yacht owners

Detailed Highlights by Article:

Article 198 – Second-Class Ships Taxation

• Complete overhaul of tax calculation for all second-class ships
• Effective from the 2024 tax year
• New scale based on gross tonnage (GRT)
• Minimum tax established

Coefficients and Categories

• New coefficients by tonnage range
• Different rates for:
  • Professional and private recreational vessels
  • Tourist day cruise ships
  • High-speed boats
  • Tugs and rescue vessels
  • Research and fishing vessels
  • Other special ships

Reductions

• Tax reductions for cargo and passenger vessels under specific criteria
• Removal of inactivity-based reductions for private recreational vessels
• Exceptions or reduced taxation for specific types of professional vessels

Article 199 – Filing Requirement

• Declaration required only if a real tax is due
• Ships with zero tax coefficient exempt
• Clarifies previous ambiguities, simplifying the process for owners and managers

Article 200 – Tax Clearance for Transfers and Registry Entries

• No transfer, mortgage, or registration allowed without full payment of:
  • Tax and contribution under Law 27/1975
  • Crew remuneration tax (where applicable)
  • Fee under Article 57 of Law 4646/2019
  • Any other applicable tax
• New owner assumes tax obligations from the transfer date
• Mechanism for assessment in case of unpaid obligations prior to registration

Article 201 – Foreign-Flagged Ships

• Declaration and taxation of foreign-flagged ships managed in Greece treated like Greek-flagged ships
• Applies from the 2023 tax year
• Tax paid abroad may be credited under conditions
• Assessment method defined for management transferred mid-year
• Strengthened documentation, recording, and reporting obligations for Greek managers

Article 202 – Exemptions and Reductions Limited

• No longer apply to:
  • Private recreational vessels
  • Professional recreational vessels
  • Tourist day cruise ships
  • All recreational small craft
• Only special exemptions for second-class ships remain