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HMRC internal manual

Tonnage Tax Manual

Tonnage tax elections: Pre-election clearance

Areas covered by clearance application

Areas covered by clearance application

This particular clearance procedure is limited to tonnage tax issues only. It does not extend to the mechanics of any reorganisation that may be required to put the group or company into the optimum position to make an election.

Examples of issues that may be addressed are:

  • whether a particular ship is a qualifying ship;

  • whether the strategic and commercial management test is met;

  • whether an activity, or part of an activity, is a qualifying activity;

  • whether an activity is a core or secondary qualifying activity;

  • how to deal with potentially non-qualifying secondary activities;

  • how to apply the 75% limit on time charters-in within a tonnage tax group;

Clearance where avoidance suspected

No clearance will be given in regard to any arrangements where it is suspected that those arrangements are made to facilitate artificial avoidance of tax.


Information to be provided to HMRC TTM02040
Timing of clearance application TTM02050
Foreign company or group TTM02060