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HMRC internal manual

Tonnage Tax Manual

HM Revenue & Customs
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Qualifying companies and ships: Non-qualifying - services normally provided on land

Examples of disallowable types of business

A vessel cannot be a qualifying ship if the main purpose for which it is used is the provision of goods or services of a kind normally provided on land.

Examples of businesses where we will apply this rule include:

  • retailers (including shops, and supermarkets)
  • restaurants
  • hotels - a ship-based holiday where the ship remains moored and there is no sea transportation element does not qualify for tonnage tax
  • prisons
  • radio stations
  • casinos - a ship that sails out of territorial waters to operate gambling facilities does not qualify for tonnage tax.
  • financial service providers
  • offices

This list is not exhaustive.


FA00/SCH22/PARA19 (2) (… services normally provided on land) TTM17101
Non-qualifying activities TTM06300