Kravet til eierfellesskap ved tildeling av strukturkvote i havfiskeflåten foreslås opphevet

25 Feb 2014

Etter dagens regler i havstrukturforskriftens § 5 er det et vilkår for tildeling av strukturkvoter at det foreligger eierfellesskap mellom fartøyet som tas ut av fiske, og fartøyet eller fartøyene som tildeles strukturkvote.

Vilkåret kan både være oppfylt ved at fartøyene tilhører samme rederi, men kan også være oppfylt dersom fartøyene tilhører ”samarbeidende rederi”, jf forskriftens § 4. Etter praksis på bakgrunn av skriv fra Fiskeridepartementet av 11.10.2002 har oppstilt krav om at det minimum må være 10 % sammenfall på eiersiden for å kvalifisere til vilkåret ”samarbeidende rederi”.

Nærings- og Fiskeridepartementet har den 3. februar 2014 sendt på høring forslag om å oppheve kravet til eierfellesskap som vilkår for tildeling av strukturkvote i havfiskeflåten. Høringsfristen er 9. mai 2014.

Forslaget innebærer at det vil være opp til rederiene seg imellom å avtale hvilke fartøy det skal søkes om tildeling av første gangs strukturkvote, uten at det samtidig må gjøres organisatoriske endringer. Søknad må imidlertid være godkjent av Fiskeridirektoratet før gjennomføring, og partene må også passe på at selskapsrettslige og skatteregler blir overholdt.

Bakgrunnen for forslaget er innspill fra Fiskebåtredernes forbund (Fiskebåt) i skriv av 21. januar og 1. mars 2013, hvor Departementet anmodes om å oppheve kravet. Fiskebåt har vist til at kravet medfører uheldige og unødvendige administrative konsekvenser, og skatte- og avgiftsmessige utfordringer som vanskeliggjør og fordyrer struktureringen av fiskeflåten.

Departementes begrunnelse for forslaget i høringsskrivet er følgende;

  1. Departementet ser ikke lenger et behov for kravet om eierfellesskap, og endringen vil gi mer ensartede regler ved at havfiskeflåten får samme regler på dette punkt.
  2. Regelverket blir enklere for rederiene i havfiskeflåten og kan spare dem for administrative kostnader knyttet til gjennomføring av eierendringer og omorganiseringer
  3. Kravet kan medføre skatte- og avgiftsmessige utfordringer
  4. Reglene blir mer forutsigbare ved at det ikke vil knytte seg usikkerhet til om vilkåret er oppfylt
  5. Forenkling for forvaltningen ved at en ikke behøver vurdere om vilkåret er oppfylt

Samtidig foreslås det at eierkonsesjonsbegrensningene for den konvensjonelle havfiskeflåten flyttes fra havstrukturforskriften § 12 annet ledd til deltakerforskriften. Dette for at alle eierkonsesjonsregler i havfiskeflåten skal være samlet i forskrifter gitt i medhold av deltakerloven (konsesjonsforskriften og deltakerforskriften).

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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