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HMRC internal manual

Tonnage Tax Manual

HM Revenue & Customs
, see all updates

Qualifying companies and ships: Person to whom chartered is not a third party

Bareboat charters-out

Bareboat charters-out are allowed in the regime if the charter is to another tonnage tax company in the same tonnage tax group. This relaxation of the general rule will cover the common situation where, for commercial reasons, a ship is owned by one member of a group but operated by another.

(See also TTM13120: this relaxation also applies to ships chartered to a partnership of which the company is a partner.)

Double charge to tonnage tax

However, if a ship is chartered from one group company to another in the same group, then they will both be charged tax on the tonnage of the ship (see TTM01320).

Single training requirement and 75%

A ship chartered from one group company to another in the same group will be taken into account only once in determining the training requirement (see TTM04001) and the 75% test (TTM05110).


FA00/SCH22/PARA18(4) (meaning of operating a ship) TTM17096
Bareboat charters-out TTM03150