Beta This part of GOV.UK is being rebuilt – find out what this means

HMRC internal manual

Tonnage Tax Manual

HM Revenue & Customs
, see all updates

Qualifying companies and ships: Qualifying company


A company is a ‘qualifying company’ for tonnage tax purposes if-

  • it is within the charge to corporation tax,

  • it operates (see TTM03100) one or more qualifying ships (see TTM03500), and

  • those ships are strategically and commercially managed in the United Kingdom (see TTM03800)

Exception - temporarily ceasing to operate qualifying ships

The only exception to this definition is that a company that temporarily ceases to operate qualifying ships may continue to be a qualifying company if certain conditions are met (see TTM03050).


A non-resident company trading in the UK through a permanent establishment (branch or agency) is within the charge to Corporation Tax, and can be a qualifying company if the other conditions are satisfied. (See TTM03800).


FA00/SCH22/PARA16 (qualifying companies and groups) TTM17086
Meaning of ‘operating a ship’ TTM03100
Definition of a ‘qualifying ship’ TTM03500
The meaning of ‘strategically and commercially managed in the UK’ TTM03800