Praksisendring skaper lønnsomhets-utfordringer for fiskeflåten

20 Sep 2012

To klagesaker for fiskeridepartementet vil avgjøre om fiskebåtrederier skal underkastes en strengere regeltolkning enn andre næringer ved vurderingen av reelt eierskap og eiernes sikkerhetsstillelse. Avgjørelsene får betydning for risiko for […]

To klagesaker for fiskeridepartementet vil avgjøre om fiskebåtrederier skal underkastes en strengere regeltolkning enn andre næringer ved vurderingen av reelt eierskap og eiernes sikkerhetsstillelse. Avgjørelsene får betydning for risiko for tilbakekall av fisketillatelser og kostnader knyttet til finansiering av kjøp av fiskefartøy.   

Fiskeridepartementet behandler nå to klagesaker som kan få betydning for fiskeflåten sine muligheter til å finansiere kjøp av fartøy og rettigheter og påfølgende tilpasninger I driftsgrunnlaget.

I den ene saken har fiskeridirektoratet lagt til grunn at det ikke foreligger et reelt eierskifte og en vesentlig del av begrunnelsen for dette standpunktet er at det var gitt selgerkreditter på oppgjøret og at det forelå avtaler om videresalg av fartøyet. Avtale om selgerkreditt og videresalg er i andre sammenhenger ikke avgjørende for vurderingen av eierskap og et prinsipielt spørsmål vil her være om jussen knyttet til overgang av eiendomsrett skal vurderes annerledes der salgsgjenstanden er et fiskefartøy. Departementet selv har i tilknytning til unntaksbestemmelser i reguleringsforskriftene sine bestemmelser å flytte et fartøy mellom to kvotesett (nybyggsregelen) uttalt at selgerkreditter kan anvendes. Opprettholder departementet direktoratet sine avgjørelser må dette også få konsekvenser for praksis knyttet til disse arrangementene.

I den andre saken er spørsmålet om en kausjon fra en minoritetsaksjeeier ovenfor rederiets langsiktige bankforbindelse, skaper et avhengighetsforhold for selskapet som ikke er forenelig med deltakerlovens forutsetning om faktisk kontroll for majoritetseier. Også her anvender fiskeridirektoratet etter vår vurdering en juss som er på tvers av alminnelige regler om en kausjonistens rolle ved finansiering.

Begrensninger i bruken av selgerkreditt og risiko for tilbakekall av tillatelser der et kjøpende rederi disponerer over fartøyet med videresalg, skaper nye utfordringer og presser lønnsomheten for rederiene. Der en kjøper av fiskefartøyet har en begrenset eierhorisont på fartøyet er det hensiktsmessig å redusere kapitalbehovet ved bruk av selgerkreditter – den muligheten begrenses særskilt for fiskeri. I tillegg får en slik praksis den utilsiktede virkning at de kapitalsterke rederiene evner å foreta tilpasninger innenfor gjeldende kvote-/strukturregime, ved at de kan egenkapitalfinansiere kjøpet og så sitte med eierskapet til fartøyet utover den periode dette er kommersielt fornuftig.

Begrensninger i kausjonsadgangen vil være særegen for fiskeri og redusere evnen til å finansiere kjøp av fartøy og øke kostnadene ved at rederiet må betale for den økte risiko som foreligger for bankene fordi sikkerhet i form av eiergarantier reduseres. Også her er det de kapitalsvake rederiene som først og fremst vil merke en slik praksis.

Vi mener at fiskeridirektoratet her praktiserer feil juss og at en slik praksis også harmonerer dårlig med deltakerlovens formål om å fremme lønnsomheten i næringen.

Advokater og næring ser frem til departementet sin avgjørelse.

Om forfatteren

Ole-Martin Lund Andreassen
Ole-Martin Lund Andreassen Ole-Martin Lund Andreassen er blant landets mest erfarne fiskeriadvokater. Han har særlig arbeidet med saker knyttet til kjøp/salg, strukturering av fartøy/rederivirksomhet, samt spørsmål knyttet til fiskerettigheter og fiskeriforvaltning.

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