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
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( 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.
Margus Tsahkna
Välisminister
Islandi väljak 1
15049 Tallinn
EESTI/ESTONIA
SENSITIVE
(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
2
SENSITIVE
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.
3
Karin Kroon Teie 29.09.2025 nr 16-11/25/4289
Kliimaministeerium Meie 14.11.2025 nr 12.1-3/4271-3
[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]
Suur-Ameerika 1 / 10122 Tallinn / 611 3558 /
[email protected] / www.rahandusministeerium.ee
registrikood 70000272