New CO2 tax on fisheries in 2025
Due to the ongoing implementation of the CO2 tax on several industries in Denmark, including the fishing sector, we have compiled what we know so far and what it means for you as a customer.
Latest update from March 12th 2025
Lubricating Oil for the Fishing Industry Subject to CO₂ Tax
In connection with the introduction of the CO₂ tax from January 1st, 2025, the Danish Tax Agency (Skattestyrelsen) is issuing new tax exemptions to both Danish and foreign fishermen.
On Friday, March 7, 2025, we became aware of the first new exemption, which indicates that the Danish Tax Agency now considers lubricating oil to be subject to the CO₂ tax.
Consequently, from March 7, 2025, we are compelled to invoice deliveries of lubricating oil to the fishing industry inclusive of the CO₂ tax, until further notice.
The CO₂ tax amounts to 2.26 DKK per liter of lubricating oil. Notably, similar to fuel deliveries, a 53% refund can be applied for in 2025.
We find it perplexing that lubricating oil products, which do not emit CO₂, are also encompassed by the new CO₂ tax. This is a matter we will continue to pursue and challenge.
The new CO2 tax
As it stands, the new tax effective from January 1, 2025, results in a gross additional cost of DKK 2.26 per liter of fuel.
Based on the guidelines from the Danish Tax authorities from January 15th, it is clearly stated, that all fishing vessels in Danish ports must pay the new CO2 tax.
As a consequence of the latest guidelines, we can not offer CO2 tax free fuel to any fishing vessels in Danish land or maritime territory within the Danish 12 nautical mile limit.
Read the latest guidelines from the Danish Tax authorities (Skat) here (Danish),
It is our strong belief, that this goes against EU regulations, and we will continue our discussions with the Danish authorities - along with other stakeholders in the industry - to find a solution that both accomodates the fishing industry as well as the environment.
Partial refund during the transition period
Due to the transition period, from 2025 to 2030, you will be able to apply for a partial refund. In 2025, the partial refund will amount to 53%, meaning the net additional cost from January 1 will be DKK 1.05 per liter of fuel.
The table below shows the refund percentage during the transition period from 2025 to 2030.
| Year | Refund in % |
|---|---|
| 2025 | 53,33 % |
| 2026 | 42,67 % |
| 2027 | 32,00 % |
| 2028 | 21,33 % |
| 2029 | 10,67 % |
| 2030 | 0 % |
According to the legislation and refund model, you will be charged the full tax on your invoice and will then need to apply for the refund yourself.
The refund application process differs depending on whether your business is VAT-registered or not.
If Your Business Is VAT-Registered in Denmark
As a VAT-registered business, you can use the refund fields available in your VAT return.
For example, if you want to claim a partial refund of your CO2 tax, you must enter the refund amount in the field labeled ‘CO2 taxes’ on your VAT return.
This means that the timing for submitting refund claims follows the deadlines for your VAT reporting.
As a business, you are responsible for calculating and entering the correct refund amount yourself.
If You Are Not VAT-Registered (Typically Foreign Companies/Fishing Vessels)
As a Non-VAT-Registered Business, You Must Obtain a Permit for CO2 Tax Refunds
First and foremost, this requires a Danish SE number. If your business is not registered in Denmark, you must complete the registration here:
Danish: 40.110 - Registrering af udenlandsk virksomhed
English: 40.112 - Registration of non-danish company
Once Your Business Has a Danish SE Number, You Must Complete a Permit Application Form to Be Eligible for a CO2 Tax Refund.
Use this form from skat.dk:
Afterwards, you can apply for a refund.
Use this form:
Important regarding exemption from energy, NOx, and sulphur taxes
All fisheries - both Danish and foreign - must now apply for tax exemption if they are not to pay energy, NOx, and sulphur taxes.
This is done using form 23.024, which can be found above.
As it stands, the above applies from January 1, 2025.
We will keep this page updated if there are any developments.
You can also contact Skat directly:
Mail: raadgiver@sktst.dk
Phone: +45 7222 1818
The content on this page is intended for informational purposes only, and Malik Energy A/S is merely passing on the information we have available. Shipowners are responsible for ensuring compliance with applicable regulations and legislation.
Fishing vessels in non-Danish ports
We can also assist if your vessel is in a foreign port. We work closely with our international trading department, enabling us to provide service and delivery outside Denmark’s borders.
Contact:
Mail: energy@malik.dk
Phone: +45 9631 3910