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HMRC internal manual

Tonnage Tax Manual

Qualifying companies and ships: Commercial management

Commercial management of a ship

This concept is undefined. But it is likely to include a range of ship and technical management activities carried out in the UK over a broad spectrum which includes the following (and where it can be demonstrated that these activities contribute substantially to economic activity and employment within the EU/EEA):

  • route planning
  • bookings for cargo or passengers
  • arranging insurance
  • arranging finance
  • personnel management
  • direction of foreign establishments
  • provisioning and victualling
  • arranging training
  • arranging repair and maintenance of vessels
  • ship superintending
  • bunker management
  • safety management
  • recruiting and managing crew
  • support facilities (e.g. training centre, terminal management)
  • ship registration/flagging
  • classification society
  • dry and wet docking management.

The test, as discussed at TTM03800, has to be interpreted purposively according to Commission guidelines and it is not possible to lay down clear rules on the extent and nature of the above criteria which must be included, but TTM03830 gives some pointers. Greater weight will be given to higher levels of decision-making and management, in contrast to routine daily management. Companies will need to review their activities in the light of the guidelines and these TTM paragraphs. In the event of a successful challenge by the Commission on grounds of unlawful State aid HMRC would be obliged to recover the aid in full and with compound interest. See Commission v Germany, Case C-70/72, ‘Kohlegesetz’ [1973] ECR 813 at [13]; and, as regards interest, Commission decision No 195/04/COL.

Vessel pools

These are explained at TTM15210.  The aim of vessel pooling is to provide cost-effective commercial management activities for a collection of similar class vessels which may be in different ownership.  The vessels typically operate under a time charter with fuel bunker and port expenses borne by the charterer and operating costs including crew, maintenance and insurance typically paid by the owner.  This type of arrangement should be regarded as consistent with retaining commercial management where indicators are satisfied looked at together.  See TTM03830.


FA00/SCH22/PARA16(1)(c) (strategic and commercial management) TTM17086
Introduction to strategic and commercial management TTM03800
Strategic management TTM03810
Additional factors TTM03830
Examples TTM03840