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HMRC internal manual

Tonnage Tax Manual

Tonnage tax elections: When election takes effect

Election made outside a window of opportunity.

The flexibility on starting date given to elections made in a further window of opportunity is not appropriate for elections made outside this window, and the election has effect from the day the company or group first qualified. See FA00/SCH22/PARA12(6).

The company’s entry into tonnage tax will trigger an end to the final pre-tonnage tax accounting period, and a new accounting period will therefore begin on the date of entry (if that date would not otherwise be the start of an accounting period. (See TTM07010).

Deferral possible where 75% limit exceeded in first AP

However, FA00/SCH22/PARA38(2) allows for deferral where the 75% limit has been exceeded in the first, or first and second, accounting periods after first qualifying. See TTM02410.


FA00/SCH22/PARA12(6) (when election takes effect) TTM17056
FA00/SCH22/PARA38(2) (election not effective if limit exceeded) TTM17231
FA00/SCH22/PARA52 (accounting period ends on entry) TTM17301