The Commission has approved the Italian ‘cuneo fiscale’ tax reduction scheme and has opened an investigation into the Polish tonnage tax scheme for international maritime transport.

Italy

The Italian scheme offers deductions from the regional tax on all types of business activities (IRAP). IRAP is a regional tax levied on the value added generated by all types of business. IRAP is computed by subtracting from revenues all intermediate costs such as salaries and raw materials.

The Commission concluded that following certain modifications adopted by the Italian Authorities, ‘cuneo fiscale’ became a general measure and so does not constitute State Aid. IRAP itself featured last year in a high profile ECJ ruling, which determined that it was sufficiently different to VAT as to be in accordance with EU rules. The Commission's current conclusion reinforces the principle that a tax break is not State Aid where available to all.

Poland

Under the Polish tonnage tax scheme, entities liable for taxes in Poland and engaged in international maritime transportation could change the tax base for their operating profits-companies fulfilling certain criteria could opt for a tonnage tax based on the net tonnage of their fleet, in place of the usual corporation tax levied on the profits derived from their maritime activities.

As the scheme foreseen by the Polish differs in several respects from previous aid of that kind already approved by the Commission, the Commission has decided to open an investigation into the differences.