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HMRC internal manual

Tonnage Tax Manual

Qualifying companies and ships: Strategic and commercial management - examples

Example 1

A wholly UK shipping company, where all management activities in relation to its ships are carried out in the UK.

This company will certainly satisfy the test.

Example 2

A company that has little commercial activity in the UK but has its registered office and the occasional board meeting in the UK.

This company will not satisfy the test.

Example 3

A company that has all strategic and commercial management of its ships in the UK, but day to day technical supervision of the vessels is in South America.

This company likely to satisfy the test, provided it can demonstrate that the UK presence fulfils the Commission’s guidelines aims mentioned at TTM03800.

Example 4

An international group operates a quarter of its fleet from the UK, through a UK sub-group. The UK sub-group has UK premises and employs around 100 staff in the UK. All technical management of the world-wide fleet is carried out in the UK, but personnel management is in the Far East. The booking system for all vessels is intranet-based using a computer in North America, but UK staff contributes a quarter of world-wide bookings. The operational board of the UK sub-group includes a majority of directors in London, but meets at various locations around the world but most meetings are in the UK.

The UK ship operating company or companies would be likely to pass the test.


FA00/SCH22/PARA16 TTM17086
Introduction to strategic and commercial management TTM03800
Strategic management TTM03810
Commercial management TTM03820
Additional factors TTM03830