Bruk av leiefartøy ved kontrahering av nybygg – forslag på høring

07 Mar 2013

Fiskeri og Kystdepartementet har den 20. februar 2013 fremmet forslag om å åpne for bruk av leiefartøy ved kontrahering av nybygg i fiskeflåten. Forslaget er i hovedsak begrunnet i ønske […]

Fiskeri og Kystdepartementet har den 20. februar 2013 fremmet forslag om å åpne for bruk av leiefartøy ved kontrahering av nybygg i fiskeflåten. Forslaget er i hovedsak begrunnet i ønske om å gjøre det enklere for enbåtsrederier å finansiere kontrahering av nytt fiskefartøy, samt oppnå målsettingen om en moderne, miljøeffektiv og klimavennlig fiskeriflåte, med bedre arbeidsbetingelser for mannskap og mer effektive fangstmetoder.

Nærmere om bakgrunnen for forslaget
Deltakerloven stiller i dag krav om ervervstillatelse for å drive ervervsmessig fiske og fangst med fartøy, jf. deltakerloven § 4. Ervervstillatelse gis til fartøyeier for ett bestemt fartøy, noe som innebærer at bruk av leiefartøy krever egen tillatelse.

Forskriftsregelverket under deltakerloven åpner i dag bare for bruk av leiefartøy ved havari og forlis. Det har vært oppfattet som rimelig at rederier som har vært utsatt for slike uhell skal kunne få mulighet til inntekter fra fiske og fangst i perioden fram til fartøyet er reparert, eller nytt fartøy anskaffet til erstatning for det forliste.

Begrunnelsen for fiskerimyndighetenes restriktive praksis med å tillatte bruk av leiefartøy er for det første at bruk av leiefartøy bryter med den strenge reguleringen hvor tillatelsen knyttes til fartøyeier og et bestemt fartøy. Ved leie er det ikke fartøyeier som driver ervervsmessig fiske med fartøyet. For det andre frykter fiskerimyndighetene at ved å tillate bruk av leiefartøy kan det legges til rette for misbruk i form av skjult kvoteleie.

Bakgrunnen for at departementet nå foreslår utvidelse av adgang til bruk av leiefartøy ved kontrahering av nybygg, er i stor grad hensynet til enbåtsrederiene som ikke får like stor nytte av reglene om kvoteutnyttelssreglenee som flerbåtsrederiene. I fiskerinæringen har det over tid vært gitt uttrykk for et behov for leiefartøy ved kontrahering av nybygg. Det har blitt pekt på at kontrahering av nybygg innebærer en stor økonomisk investering som det kan være utfordrende for et fiskebåtrederi å finansiere. Dette gjelder særlig enbåtsrederier, som ved nybygg foretar utskifting av virksomhetens samlede driftsmidler. En god salgspris på fartøyet som skal erstattes vil være viktig for finansieringen av nybygget, og det vil etter omstendighetene kunne være nødvendig å selge fartøy i god tid før levering for å oppnå best mulig pris. Hvis fartøyet selges før levering, vil rederiet kunne søke om utskiftingstillatelse i ventetiden, men en slik utskiftingstillatelse gir ikke rett til å fiske og kan heller ikke danne grunnlag for søknad om bruk av leiefartøy. Rederiet risikerer således bortfall av sine fiskeriinntekter i en periode.

Lempingen på kvoteutnyttelsesreglene de siste årene skulle ivareta mye de samme hensynene, men forslaget fra Departementet innebærer en erkjennelse av at dette ikke vil være tilstrekkelig, samt at kvoteutnyttelsesreglene skaper nye utfordringer knyttet til skatte- og regnskapsregler.

Innholdet i forslaget
Vilkårene for å kunne benytte seg av den foreslåtte ordningen med leiefartøy ved kontrahering av nybygg er for det første at rederiet har inngått bindende kontrakt om kjøp av nybygg med levering senest om to år. Det åpnes imidlertid for bruk av leiefartøy ved forsinket levering, dersom forsinkelsen skyldes forhold utenfor rederiets kontroll, altså tilsvarende praktiseringen av regelverket etter dagens kvoteutnyttelsesregler.

For det andre mener Departementet at det må stilles krav til at fisket med leiefartøyet skjer for leiers regning og risiko, tilsvarende det som gjelder ved bruk av leiefartøy ved havari og forlis. Vilkåret er begrunnet med at det er nødvendig for å hindre skjult kvoteleie.

Endringer av kvoteutnyttelsesreglene
Som følge av forslaget om å åpne for bruk av leiefartøy ved kontrahering av nybygg, foreslås det å endre/oppheve deler av kvoteutnyttelsesreglene, og det bes videre om høringsinstansenes syn på om dagens instruks av 9. oktober 2012 om kvoteutnyttelsesregler bør oppheves eller videreføres. Bakgrunnen er at Departementet frykter at kvoteutnyttelsesreglene har den ulempe at det over tid kan danne seg grunnlag for skjult strukturering, særlig i rederier med mange tillatelser. Dessuten har Departementet merket seg at det fra enkelte hold er stilt spørsmålstegn ved om flerbåtsrederier skal ha gunstigere og mer forutsigbare ordninger når det gjelder bruk av midlertidig fartøy i nybyggingsperioden enn andre rederier som er organisert på annen måte.

Høringsfristen er fredag 5. april 2013

Om forfatteren

Olav Egil Midtgaard
Olav Egil Midtgaard Olav Midtgaard har 11 års erfaring som advokat, er med i fiskerigruppen i SANDS, og har sitt hovedarbeidsområde innenfor selskapsrett og transaksjoner. Olav har bred erfaring fra fiskeribransjen, og har bistått en rekke fiskebåtrederier og skipsmeglere med bl.a. oppkjøp, restruktureringer, strukturering av fiskerikvoter, generasjonsskifter og løpende dialog med fiskerimyndigheter knyttet til melding om eierendringer, strukturering mv. Olav har dessuten jobbet med flere problemstillinger knyttet til aktivitetskravet i deltakerloven og skattesaker vedrørende strukturering av fiskerikvoter. Olav har også bred erfaring knyttet til fiskeoppdrett og har bistått både landbaserte og sjøbaserte oppdrettsvirksomheter med både salg og oppkjøp/due diligence, samt i forhold til skattemyndigheter vedrørende FOU-prosjekter og eiendomsskattetvister.

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