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HMRC internal manual

Tonnage Tax Manual

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HM Revenue & Customs
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Introduction to tonnage tax: Tonnage tax profits

Multiple interests in same ship at different levels

Multiple interests

Two (or more) companies may be regarded as operating the same ship for tonnage tax purposes. For example if a ship is owned by one company and time chartered to another, they will each be regarded as operating that ship. (See TTM03100 for the meaning of ‘operating a ship’).

Where two or more companies are regarded as operating the same ship because they have different interests in it, then each of them will each have its tonnage tax profits calculated as if it were the only operator, even if they are in the same tonnage tax group.

This treatment does not apply where two or more companies are regarded as operating the same ship because they share the same interest in it (see TTM01310).

Example

A ship, with a net tonnage of 17,371 tons, is owned by Company A. Company A bareboat charters the ship to Company B (in the same tonnage tax group), and company B time charters the ship to an unrelated company, Company C, for the whole of the year ended 31 December 2013.

The ship’s profit for the accounting period ended 31 December 2013 is £24966 (see the example in TTM01300). Each of the three companies is regarded as if it were the only operator of the ship for the purposes of calculating their tonnage tax profits. And they will each need to include the full amount of £24966 in their tonnage tax profits for the accounting period ended 31 December 2013.

References

FA00/SCH22/PARA5(2) (calculation in case of joint operation) TTM17021