The Taxation of Greek Shipowners in the Post-War Greek Reconstruction
Vassilis Patronis & Apostolos Vetsopoulos
University of Patras, Greece
In this paper we aim to analyze the taxation of Greek ship-owners in the post-war Greek reconstruction, which became a very thorny question to be settled between the Greek government and the Union of the Greek ship-owners, who they had at that time established their head quarters in New York and London.
We are going to examine the problems, which emerged in the efforts of the Greek government to persuade the ship-owners to pay the enforced taxes on the merchant marine earnings after the World War II. The cause of this dispute was that the ship-owners did not accept the amount of enforced taxes, because they considered them very high and beyond of their ability to pay in a post-war period.1
In the beginning, the analysis will be focused on the activities and the taxation of the Greek ship-owners in the inter-war period in connection with the losses of Greek merchant fleet during the World War II and the relations between the Greek government in exile established in London and the Union of Greek ship-owners. In this period the origins of the question on merchant marine taxation emerged.
The second part of the analysis will explore the efforts of the Greek government to impose taxes on the merchant marine earnings. In the post-war period the assignment of Liberty ships by the USA Administration to the Greek ship-owners through the guarantee of the Greek state strengthened the position of the Greek government to impose taxes on the earnings of the Greek ship-owners after the liberation of the country through the enforcement of relevant legislation of the Greek state. Nevertheless, the Greek ship-owners were reluctant to pay down their own taxes, while the Greek state’s authorities were unable to implement the relevant taxation laws and to collect taxes on the earnings of the Greek ship-owners.
The third issue of the analysis will deal with the efforts of the American Marshall planners to assist the Greek government to collect taxes on the merchant marine earnings. Because the Greek state was losing a great amount of revenue from taxation on maritime activities, which was necessary for the reconstruction of the country, the mediation of the American Marshall planners to arrange the Greek state-ship-owners dispute led to the final settlement of the issue.
At the end the analysis will deal with the efforts of the Greek government to stimulate the ship-owners to bring their own ships under the Greek flag. In 1951, after common initiative of ship-owners and government’s members, although the Greek government decided to decrease considerably the amount of taxes on the Greek ship-owners activities in exchange for registration of their own ships under the Greek flag through the introduction of the law 1880/1951, the Greek ship-owners were reluctant to transfer their own ships from the flags of convenience to the Greek flag.
During the 19th century the Greek merchant fleet prospered and by 1939, despite the losses in the First World War, was the third largest in the Mediterranean and the ninth in the world. The ships were mostly second hand and in 1939 over 75 per cent were very old of 20 years. Because the captains chose their crews from their own relatives paid them poorly, leaving a large part of the earnings to the ship-owners. In the interwar period, although a large part of these earnings never reached the country, the net revenue of the Greek government from this source of commercial activities in a good year was about $12 million, which was a great contribution to the balance of payments each year. The total tonnage of the Greek merchant marine was 1,837,000 tons, including 500 ocean-going vessels, 55 larger ships of coastal and Mediterranean fleet and 733 small caiques.2
After the great economic recession of 1928, not only the value of Greek exports fell from a yearly average of $125 million in 1922-30 to only $49 million in 1933, but also the receipts from shipping and the emigrants decreased sharply. Since the merchant marine activities faced problems, the Greek Government tried to facilitate the Greek ship-owners to overcome the economic crisis, which was higher than that in the other countries. The most significant measure was the government’s decision to relieve “of taxation the net earnings of merchant marine in order to reinforce its position in the international market”.3 The grounds of the original dispute between government and ship-owners emerged in the war-time circumstances. After the outbreak of the World War II, as the naval transport was a very profitable operation from the very high freights because of the war dangers, the Greek government in exile in London asked the ship-owners to contribute fairly to the extraordinary state expenses, paying down taxes on the net earnings or other type of taxation. As the country was occupied and exploited by the forces of Axis, the taxation of Greek merchant marine was a principal source of revenue for the Greek government in exile resided in London and with the evolvement of Greece in the war, the government enforced a taxation law on the merchant marine earnings. The Union of ship-owners established in London considered this law unfair and asked its change.
Under these circumstances, in order to create a climate of confidence and cooperation, the government in December 1941 introduced a new law (Emergency Law 3074) that was accepted from the Union of ship-owners and the Naval Committee, which was a common body of Greek government and ship-owners representatives, since the basis of taxation took in account the dead weight (d.w.) and not the gross tonnage (g.t.) of the ship. However, apart from small exceptions, the majority of ship-owners, inclined to the constant increase of their profits, did not show a sense of the critical situation of nation and refused systematically to pay down their taxes, which were very small and on a favourable basis for them. They retained this stand, “because they considered that the Greek government had legal rights in the foreign land, but it was unable to enforce them”.4 In the first years of implementing the law only an amount of nearly £350.000 was collected annually. The minister of Finance and Merchant Marine Kyriakos Varvaressos faced the hostility of the ship-owners, who considered him as a fatal enemy of their own interests, as he was the responsible politician not only for the introduction of the relevant law but also for the signed agreement between the Greek and the British governments, which enforced compulsory freight of the remaining ships of the Greek ship-owners by the British War Transport, which were not freighted by the Swiss government. According to this agreement the British government was obliged to pay down apart from the price-freight to the ship-owners further £1.000.000 annually to the Greek government. The ship-owners considered that this agreement exploited their own merchant marine activities and limited their free status. Thereafter, Varvaressos devoted himself in the efforts of the government to force the ship-owners to pay down their taxes. As the World War II was over and the European nations had to reconstruct the devastated infrastructure and rebuild their economy from the war destruction, Greece needed to take an important step to reduce budget deficit and to find effective means of preventing tax evasion. While the Greek merchant marine was valued at only $50,000,000 in 1939, the activities and losses in the war so increased the value of ships that in 1946 Greek ship-owners hold an estimated $108,000,000 in blocked sterling accounts in London resulting from insurance benefits, as well as an almost equal amount of earnings in blocked and unblocked foreign currencies. Therefore, the prosperous Greek merchant marine was able to contribute fairly to the budget and the balance of payments deficits.
Because the capacity of the Greek merchant marine had been reduced from 1,800,000 to 700,000 tons by the end of the World War II, in order not only to facilitate the replacement of destroyed tonnage, but to assist the recovery of the Greek economy, the United States Maritime Commission in 1946 and 1947 sold 100 Liberty ships and 7 T-2 tankers to Greek ship-owners. However, the financial benefits to the Greek state revenues of the merchant marine activities were less than the fleet size, since the vessels largely operated out of foreign ports and the whole business was conducted in foreign exchange. Also, about only 20% of the gross earnings returned to Greece in wages, taxes and net profits. Despite the generous assistance of the Greek state, which became the guarantor of loans to many ship-owners who bought Liberty ships on extremely easy terms of payments and at a cost of 25 percent of their original value, the ship-owners declined to pay the agreed level of taxes-12% of net earnings ($8.000 per year for any Liberty ship), which were smaller in comparison with the proportion of taxes that other countries had applied in accordance with international contracts. Since the net yearly earnings of these ships, estimated from Government officials and British experts, amounted to over than $200.000, the terms of the agreement between the Greek government and ship-owners were adverse to the interests of the Greek state and was out of the principal aim of the American administration to increase the foreign exchange reserves of Greece. However, “this deal not only stimulated Greek shipping but also aided general recovery greatly by providing more tonnage to bring aid supplies to Greece.”5
The terms of the agreement, which concluded in favour of the Greek ship-owners, were condemned by many Greek and foreign officials and authorities. The British Economic Mission established in 1946 expressed its dissatisfaction and called for implementing a reasonable taxation on the merchant marine earnings. When a Greek minister asked the assistance of Varvaressos, who was in service at the World Bank in Washington D.C., to support the purchase of Liberty ships in November of 1946 through the members of the Committee in the National Advisory Council, Varvaressos gave his assistance to this request, but he asked the minister to undertake a new effort to change the scandalous terms of the agreement. The Currency Committee, an independent body, established in 1946 besides the Bank of Greece advised the Greek government, after consulting the American Economic Mission of Paul R. Porter, in February 1947 that the amount of yearly taxes for each Liberty ship should be $30.000 and $75.000 in foreign exchange. Porter Mission, sent by the State Department, with exploratory character came to Greece for three months in the beginning of 1947 to examine the economic problems of the country. Also, the Secretary of State Acheson was involved in this question, when in April 1947 he asked the postponement in introducing the relevant law until the American Mission for Aid to Greece (AMAG) arrives in Greece in July 1947 under the Truman Doctrine (July 1947 to June 1948). Acheson supported the idea that the collected taxes and foreign exchange from the Greek government for the Liberty ships should increase considerably. Furthermore, another argument was that since the Greek ship-owners placed most of their new and very lucrative businesses under foreign flags and hoarded their vast profits in foreign banks, they evaded taxation. An American scholar emphasized that a lot of these millionaires resided in opulence in fashionable Kolonaki, section of Athens and “others lived in great luxury in New York City, where they remained free of taxation by U.S. authorities as well through use of Greek diplomatic status”.6
The head of the transport division Cedric Seager of the American Mission for Aid to Greece in cooperation with Myron Black, a State Department adviser on shipping issues, who came to Greece from the US Embassy at Rome tried for six-months to persuade the Greek authorities to revise the terms of the agreement with the ship-owners, while the latter refused to make discussions on the taxation issue. After American Mission for Aid to Greece’s pressure the Greek government introduced the law 567 in March 1948, which determined a taxation of 40% of net merchant marine earnings and for 1947 enforced $13 million taxes. However, the ship-owners avoided paying down their own taxes apart from an exception and went to court and after to the High Court, which cancelled the relevant law. The reasoning of ship-owners expressed through letters: they argued that the Greek flag was extremely expensive prejudicing their commercial activities and the Greek crews were the second more expensive in the world. Certainly, the Greek government was not responsible for the failure of not collecting taxes from the merchant marine earnings because of the austere plan of taxation as a scholar7 recently asserted, but the established connections between Greek politicians and ship-owners were the most responsible for the loss of valuable foreign exchange and taxes from these sources. Therefore, although the taxation of merchant marine earnings was reasonable and moderate, the Greek ship-owners avoided in paying down their own taxes, “while the Greek authorities showed an unreasonable inability or reluctance to implement the relevant law and constantly receded to the demands of ship-owners”.8
In the beginning of 1949 as the merchant marine earnings were enormous and the issue on taxation of these earnings was in a stalemate, the Greek government decided to introduce an Emergency law No 887/12 February 1949, which amended and supplemented the provisions of the former legislative Decree No 567/ March 1948 in order to press the ship-owners to pay down their own due taxes in order to increase the amount of collected taxes to decrease the budget and the balance of payments deficits. It showed its determination to achieve this objective, insisting that all elements in the nation must contribute their fair share towards national recovery, while the ship-owners taxes were for four years in arrears. Beginning in the summer of 1949 the Greek government tried to exercise punitive measures against ship-owners, such as ordering Greek consuls abroad to refuse visas and shipping documents to delinquent Greek flag ship-owners. The Economic Cooperation Administration in Greece (ECA/G), which was the successor Mission of the AMAG, was established in July 1948 for four years to implement the Marshall Plan, did not approve of these partial measures. Eventually, the Mission decided to mediate in the long dispute between the Greek government and ship-owners union in Athens over taxation and other matters affecting the welfare of the Greek merchant marine, encouraged from the decision of government’s members to solve the problem. After the acceptance of the Economic Cooperation Administration / Mission in Greece proposal by the Government, Myron Black, the State Department shipping adviser at the Rome Embassy, was called again as in the previous year to proceed to Greece for a ten-day conference to contribute to settle the issue. At the end of January 1950, after the Economic Cooperation Administration’s pressure in Washington D.C., George Mantzavinos, Governor of the Bank of Greece, visited London and New York “to obtain settlement with Greek shipowners concerning deliquent taxes.” 9
These discussions and contacts between the concerned parties led to the introduction of the new emergency law 1411 by the Caretaker Government of Theotokis in February 1950 and passed in Parliament on 23th February, which settled the outstanding question of taxation on 1947 and 1948 earnings of Greek merchant marine. According to the law payment of the tax assessed will be made in 5 installments in 1950 and the first installment of the shipowners’ tax was due before the end of March 1950 10, while for the ships on which taxes were not paid will be denied shipping papers by Greek Consuls abroad. The passing of this law caused dissatisfaction among ship-owners, who in protest against ‘crushing taxation’ dissolved the Union of Ship-owners. On the last day of March only a few ship-owners, and no liberty ship-owners, had paid. The Ministers of Finance and Mercantile Marine and the Prime Minister therefore sent directives to ship-owners’ organizations and Greek Consuls in New York and London that legal sanctions would be taken against those who had not paid the first installment by April 15.
On 25 April 1950 Porter, the Chief of the Economic Cooperation Administration / Mission in Greece, expressed to the Secretary of State, Economic Cooperation Administration in Washington D.C. and Economic Cooperation Administration in Paris the willingness of its Mission to support the Greek government in taking these measures. The collection of these taxes was required to reduce the deficit in the budget and constituted a moral issue, supporting the governmental efforts to increase revenue taxes. The payment of these taxes was also a major source of foreign exchange. The Economic Cooperation Administration in Greece supported the idea that “the Greek shipowner, no less than the individual Greek farmer, merchant or workman, should shoulder his fair share of the operating costs of the Greek nation, which gives him the sanction and protection of his flag”.11
On 2 May Porter instructed the State Department about the compromise settlement between the Greek government and the shipowners. After consultation with Stavros Livanos, a leading Greek shipowner from New York, Venizelos, who was a political leader, had suggested a compromise settlement of $10 million to cover the tax liability of all shipowners for the two years of 1947 and 1948, and he threatened to withdraw his Liberal Party’s support from the present Centre Coalition Government if the latter did not accept his proposal. The Government had estimated a tax liability of shipowners to be about $15 million and they proposed $12.5 million.12 In the Office of Porter an agreement was reached on 29 April 1950 between the Greek Ministers of Finance and Mercantile Marine and a group of shipowners, who claimed that they represented approximately 45 percent of the Greek tonnage involved. Eventually, the Greek government, confronting its own fall, was forced to accept Venizelos’ proposal. However, according to another term of the compromise settlement, those shipowners, who were not able to pay within the stipulated time limits, had “to suffer consequence of increases and penalties under Law 1411 and as last resort their vessels to be seized by Greek Government and sold at auction.”13 After the threat of Venizelos to withdraw his party’s support from the Coalition Government, Porter considered it his duty to insist on a settlement more favourable to the Greek Government, and indirectly to US interests than this compromise proposed by shipowners in the previous August, which was smaller than that of $10 million. In June 1950, with the support and pressure of the Government’s members, such as “Karamanlis, Tsatsos, Averoff and Mavros,”14 Porter also succeeded in persuading the Government to force the ship-owners to pay their own current taxes, even though many government officials, such as Venizelos and Papapolitis, were dependent on the ship-owners, since they were “interlocked with them by marriage, family relationships. The amount of taxes that were collected was about 17 million dollars in one week”.15 Nevertheless, although the taxation of ship-owners ought to have risen from $8,000 to $30,000 annually, since their annual net earnings amounted to between $200,000 and $250,000 according to foreign experts, their political influence frustrated any effective action.
In the beginning of 1951 heavy delinquency on taxation among Greek flag ship-owners emerged, which was dissipated after strong action of the government. When the latter ordered Greek Consuls throughout the world to refuse the provision of passage papers to Greek flag ships, which had not paid their taxes, the ship-owners were forced to pay down their back taxes in full. They paid 40 billion drachmas (national Greek currency) for 1950 and by the end of 1951 more than 100 billions drachmas on their 1951 operations. For the first time since World War II this development brought ship-owners’ tax collections completely up to date. However, much of the effect of this action dissipated in the summer 1951, when the introduction of a new law (Emergency Law 1880/28 July 1951) reduced the ship-owners’ confirmed taxes for collection to about one-fourth of rate of the previous law, because it changed the existing taxation system on net earnings and adopted a new taxation system on gross earnings. Although this action theoretically aimed to attract to the Greek flag ships, which were registered with foreign flags of convenience, the results proved to be negative and the influence of the ship-owners establishments on the politicians of the Coalition Government of the Centre to relieve them on the burden of taxes was hidden in the introduction of the new law. Therefore, the foreign exchange receipts of Greek state from the taxes on the merchant marine earnings diminished.
In the final fiscal year 1951-52 of Marshall Plan in Greece, when the foreign aid was to terminate and the enormous balance of payments deficit had to be reduced, because a great part of the latter was financed through the Marshall aid, Greek Government should try to secure valuable foreign exchange through the increase of exports and invisible receipts. At the same period, although the foreign exchange earnings increased in comparison with the previous year, mainly because the Greek importers were forced to repatriate a part of the internal capital from the cut in credits, and the balance of payments deficit improved, the earnings from the Switzerland after taxation of the ship-owners decreased because “the enforced taxes regulation in the previous years had led ship-owners to register their ships under foreign flag”.16 The results of this unpatriotic action by the ship-owners deprived the Greek budget of considerable revenue and dollar earnings at a critical period for the stabilisation of the Greek economy, and Greece also lost its ranking as third largest in the world among the countries with merchant fleet. While at the end of 1950 the total Greek-owned ocean-going shipping consisted of 989 ships with a gross tonnage of 5,560,134 of which only 337 ships were under Greek flag, by December 1951 these ships amounted to 1103 with a gross tonnage of 6,427,098, of which only 331 ships were under the Greek flag. Therefore, the introduction of the Emergency Law 1880/28 July 1951, which decreased the taxation of the Greek ship-owners in order to encourage them to bring their ships under the Greek flag, resulted not in an increase, but in a decrease of the number of ships putting up the Greek flag. In the next year 1952 the ship-owners did not change their habit, as only 12 ships changed their flag and were registered in the Greek flag by the end of 1952.
Concerning the decision of the Greek government through the enforcement of the Emergency law 1880/28-7-1951 to decrease the taxation on the merchant marine earnings, Varvaressos, who was in service by the World Bank in Washington D.C. and at the same time he was entrusted by the Greek government with an important mission to submit a report on the economic problem of Greece, condemned the relevant law as a discriminatory legislation, because it was not in service to the interests of the state, but those of ship-owners. He supported the idea that “as the country faces enormous expenses in foreign exchange…and the division of taxation burden should become more fair…how the government passed a law in order to reduce greatly the taxation on the earnings of merchant marine. The Greek merchant marine collects very enormous profits”.17 Furthermore, the new law 1880 of 1951 changed fully the existing taxation system on net earnings and introduced a new taxation system on the gross earnings. Because the determined taxation factors of the new law were much lower of those of the previous taxation system, the confirmed taxes for collection amounted only to ¼ nearly of the former taxation on the condition the number of ships under Greek flag will remain the same.
Because the deficit of the budget and the balance of payments was enormous, and tax evasion was very high, the issue of preventing this practice was of great economic and social importance for the Greek government. Among the classes, who used to resort in tax evasion, was that of the ship-owners as their tax evasion was notorious and scandalous. The experienced economist Varvaressos, who was expert in estimating the profits of merchant marine activities, recommended to the government that the ship-owners should lose their Greek nationality if they continued to devote themselves to such practices. While in 1951 the real income of commercial and industrial classes was doubled in comparison with the pre-war year of 1939, in the same period their contribution to the country’s revenue through taxation decreased by half.
In conclusion, the contribution of the Greek ship-owners in the post-war Greek reconstruction was very small, because their share on collected taxes by the relevant authorities in comparison with other classes of the Greek society on the grounds of earnings was negligible. Although the Greek ship-owners made a great part of their earnings abroad and not in the sphere of internal economic activities, however, their reluctance to pay down their own taxes was not justified, given the enormous increase of their revenues and their investments in launching new ships during the late 1940s and 1950s. Therefore, as the valuable foreign exchange, which could finance necessary imports, reducing the balance of payments deficit, was absent from the country, the Greek government delayed in succeeding to stabilize the Greek economy, because a great part of the foreign aid went to import consumer goods and not to finance reconstruction projects.
Bibliography
Unpublished Archival Sources
National Archives, Washington D.C.
Record Group 469, Records of the US Foreign Assistance Agencies, 1948-61
Harry S Truman Presidential Library, Independence, Missouri
Oral history Interview: Paul R. Porter: Chief, ECA Mission to Greece, 1949-1950; Assistant Administrator, ECA, 1950-1951; and Deputy US Special Representative in Europe, Mutual Security Program, Paris, France, 1952-53.
Public Record Office, Kew Gardens, London
FO 371-Political Correspondence
Bank of Greece, Athens
Αρχείο Κυριάκου Βαρβαρέσου (Archive of Kyriakos Varvaressos)
Official and Government publications
Εφημερίς της Κυβερνήσεως (Official Gazette of the Greek Government), vol. 1947-1951
Personal communications:
James Warren Jr.: Letters and personal interviews
Paul R. Porter: Letters to Apostolos Vetsopoulos, 5th January 2001.
Unpublished theses
Vetsopoulos, Apostolos, The Economic Dimensions of the Marshall Plan in Greece, 1947-1952: The origins of the Greek economic miracle, PhD dissertation submitted to the University of London from the University College London (UCL), 2002.
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Notes
1 Apostolos Vetsopoulos, The Economic Dimensions of the Marshall Plan in Greece, 1947-52: The Origins of the Greek economic miracle”, Unpublished PhD thesis, University of London, 2002, p. 189.
2 MSA/G, The Story of the American Marshall Plan in Greece, July 1, 1948 to Jan. 1, 1952, Press Release No 1300, July 20, 1952, Lincoln Papers: Box 8: Truman Library, p. 52.
3 Archive of Kyriakos Varvaressos, Bank of Greece, B/1.
4 Archive of Kyriakos Varvaressos, Bank of Greece, B/1.
5 The Story of the American Marshall Plan in Greece, July 1, 1948 to January 1, 1952, p. 52.
6 Wittner, Laurence, American Intervention in Greece, 1943-1949 (New York: Columbia University Press, 1982), p. 176.
7 Stathakis, George, (To dogma Truman & to Sxedio Marshall), The Truman Doctrine & the Marshall Plan, (Athens: Vivliorama,2004), p.246.
8 Varvaressos, Kyriakos, (Ekthesis epi tou oikonomikou problematos tis Ellados), Report on the economic problem of Greece (Athens : 1952), p. 141.
9 Porter to Hoffman, 27 January 1950, RG 469 / 1208 / Box 25 / file 6 / NA.
10 The Official Gazette of the Greek Kingdom, 24 February 1950, Athens, First Volume, Issue 56: Emergency Law 1411 concerning the taxation of mechanically operated Greek ships for the fiscal years 1947-48 and 1948-49.
11 Porter to ECA/W, 25 April 1950, RG 469 / 1208 / Box 21 / NA.
12 These data are taken from Porter to the Secretary of State, 2 May 1950, RG 469 / 1208 / Box 21.
13 Porter to Secretary of State, 2 May 1950, RG 469 / 1208 / Box 21 / NA.
14 Letter of Paul R. Porter to Apostolos Vetsopoulos, 5 January 2001.
15 Oral History Interview with Paul R. Porter by Richard McKinzie & Theodore Wilson, p. 60, Truman Library.
16 Apostolos Vetsopoulos, The Economic Dimensions of the Marshall Plan in Greece, 1947-52: The Origins of the Greek economic miracle”, Unpublished thesis, University of London, 2002, p. 322.
17 Varvaressos, Kyriakos, Ekthesis epi tou Oikonomikou Problimatos tis Ellados, (Report on the economic problem of Greece), (1952), (Athens, 2002) p. 141.
