Vastus pöördumisele

Margus Tsahkna

Välisminister

Islandi väljak 1

15049 Tallinn

EESTI/ESTONIA

EUROPEAN COMMISSION

Brussels,10.11.2025

C(2025) 7685 final

SENSITIVE (*): COMP Operations

Subject: State Aid SA.120534 (2025/N) – Estonia

Amendments to State aid in favour of maritime transport

Excellency,

1. PROCEDURE

(1) On 1 October 2025, Estonia notified the prolongation of an existing aid scheme

in favour of the maritime transport sector (“the existing aid scheme”), as approved

by Commission decision of 16 December 2019 in case SA.53469 (2019/N) (1) –

State aid in favour of maritime transport (“the original decision”).

(2) Estonia exceptionally agrees to waive its rights deriving from Article 342 TFEU,

in conjunction with Article 3 of Regulation 1/1958 (2) and to have this Decision

adopted and notified in English.

2. DESCRIPTION OF THE SCHEME

2.1. Background

(3) The existing aid scheme is set to expire on 30 June 2026.

(4) Under the existing aid scheme, the maritime transport industry can benefit from a

special taxation scheme for maritime transport activities carried out by ship

operators and ship managers (“the tonnage tax scheme”) as well as a scheme

partially reducing labour-related costs for seafarers and their employers involved

in such maritime transport activities (“the seafarer scheme”).

(*) Distribution only on a need-to-know basis. Do not read or carry openly in public places. Must be

encrypted in transmission and stored securely, where possible by using encrypted storage. Destroy

copies by shredding or secure deletion. Full handling instructions: https://europa.eu/!db43PX

(1) OJ C 144, 30.4.2020, p. 9.

(2) Regulation No 1 determining the languages to be used by the European Economic Community, OJ

17, 6.10.1958, p. 385.

SENSITIVE

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(5) The purpose of the existing aid scheme is to raise the international

competitiveness of the European shipping industry and maritime sector as a key

sector of the economy in the international market.

2.2. Legal basis

(6) The national legal basis of the existing aid scheme is composed of the Income Tax

Act, the Social Tax Act, the Funded Pensions Act, and the Unemployment

Insurance Act.

2.3. Budget and duration

(7) Estonia seeks to prolong the existing aid scheme for a further six years, (i.e., from

1 July 2026 to 30 June 2032) with a total estimated budget of EUR 18 million.

This amount consists of an estimated EUR 6 million for the tonnage tax scheme

and an estimated EUR 12 million for the seafarer scheme, compared to an

estimated budget of EUR 2.3 million and EUR 177 million, respectively, for the

2020 to 2024 period.

(8) Apart from the prolongation of the existing aid scheme until 30 June 2032 and the

amended budget, Estonia confirms that no further amendments are proposed to

the existing aid scheme and that all other conditions of that scheme remain

unaltered.

3. ASSESSMENT OF THE MEASURE

3.1. Existence of State aid within the meaning of Article 107(1) TFEU

(9) For a measure to be categorised as aid within the meaning of Article 107(1) TFEU,

all the conditions set out in that provision must be fulfilled. First, the measure

must be imputable to the State and financed through State resources. Second, it

must confer an advantage on its recipients. Third, that advantage must be selective

in nature. Fourth, the measure must distort or threaten to distort competition and

be liable to affect trade between Member States.

(10) The existing aid scheme constitutes State aid within the meaning of Article 107(1)

TFEU for the reasons set out in recitals (59) to (64) and (127) to (129) of the

original decision. The notified prolongation does not affect that conclusion, as the

only amendments to the existing aid scheme concern its duration and budget. The

Commission therefore refers to the respective assessment contained in the original

decision and concludes that the existing aid scheme, as amended, constitutes State

aid within the meaning of Article 107(1) TFEU

3.2. Compatibility of the measure pursuant to Article 107(3), point (c) TFEU

(11) Pursuant to Article 107(3), point (c) TFEU, aid to facilitate the development of

certain economic activities or of certain economic areas may be considered

compatible with the internal market, where such aid does not adversely affect

trading conditions to an extent contrary to the common interest.

(12) The Commission has issued guidelines for the application of Article 107(3), point

(c) TFEU with regard to State aid to maritime transport (“the Maritime

SENSITIVE

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Guidelines”) (3). Aid in favour of the maritime sector must therefore be examined

in the light of these guidelines.

(13) The prolongation of the existing aid scheme until 30 June 2032 and the change in

its budget do not alter the assessment of the Commission that the measure

complies with the conditions of the Maritime Guidelines, as laid down in sections

3.1.3 and 3.2.3 of the original decision. Furthermore, the proposed amendments

do not affect the proportionality of the measure.

(14) On this basis, the Commission concludes that the proposed prolongation and

change in budget do not affect the evaluation of the compatibility of the existing

aid scheme with the internal market.

4. CONCLUSION

The Commission has accordingly decided not to raise objections to the aid on the grounds

that it is compatible with the internal market pursuant to Article 107(3) point (c) of the

Treaty on the Functioning of the European Union.

If this letter contains confidential information which should not be disclosed to third

parties, please inform the Commission within fifteen working days of the date of receipt.

If the Commission does not receive a reasoned request by that deadline, you will be deemed

to agree to the disclosure to third parties and to the publication of the full text of the letter

in the authentic language on the Internet site: https://competition-

cases.ec.europa.eu/search?caseInstrument=SA.

Your request should be sent electronically to the following address:

European Commission,

Directorate-General Competition

State Aid Greffe

B-1049 Brussels

[email protected]

Yours faithfully,

For the Commission

Teresa RIBERA

Executive Vice-President

(3) Commission Communication C (2004) 43 – Community Guidelines on State aid to maritime

transport, OJ C 13, 17.01.2004, p. 3.

Suur-Ameerika 1 / 10122 Tallinn / 611 3558 / [email protected] / www.rahandusministeerium.ee

registrikood 70000272

Karin Kroon

Kliimaministeerium

[email protected]

Komisjoni otsuse edastamine

Austatud proua Kroon

Edastame Euroopa Komisjoni 10.11.2025. aasta otsuse SA.120534 (2025/N) Amendments to

State aid in favour of maritime transport.

Vastavalt komisjoni otsuse osale 4 tuleb Euroopa Komisjoni teavitada 15 tööpäeva jooksul

otsuse kättesaamisest, kas otsuses on konfidentsiaalset infot. Oleme saanud

Kliimaministeeriumilt 13.11.2025 e-kirjaga kinnituse, et otsuses konfidentsiaalset infot pole

ja edastame selle teabe Euroopa Komisjonile.

Lugupidamisega

(allkirjastatud digitaalselt)

Kaur Kajak

halduspoliitika asekantsler

Lisa(d):

Komisjoni otsus SA.120534

Maris Kalda 5885 1434

[email protected]

Teie 29.09.2025 nr 16-11/25/4289

Meie 14.11.2025 nr 12.1-3/4271-3