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HMRC internal manual

Tonnage Tax Manual

The training requirement: Description

Initial and annual training commitments

Initial training commitment

Before election into tonnage tax companies or groups must prepare an initial training commitment by completing a series of Department for Transport forms showing the proposed officer training they intend to undertake.

Minimum training obligation

Unless covered by PILOT, the minimum training obligation each year will be to commence the training of one eligible officer trainee for each 15 posts in the effective officer complement (rounded up or down).  The training of such an officer may take one, two or three years depending on previous experience.

Safe manning complement

This complement is based on the safe manning documents (SMD) of each ship plus 50%.  Where the vessels are under 500 gross tons and do not require a safe manning document the effective officer complement for each is deemed to be two.  For other cases, where there is no SMD, DfT will seek advice from the Maritime and Coastguard Agency.

Annual training commitment

The annual training commitment is similarly constructed.

Certificate of compliance issued by DfT

If satisfied by an application DfT will issue a certificate under FA00/SCH22/PARA26(2) or PARA27(2) to the effect that the company or group has met its minimum training obligation.


FA00/SCH22/PARA26 (initial training commitment) TTM17171
FA00/SCH22/PARA27 (annual training commitment) TTM17176
SI00/2129/REG2 (safe manning document) TTM19002
SI00/2129/REG8 (the training commitment) TTM19008
FA00/SCH22/PARA24 (minimum training obligation) TTM17161
SI00/2129/REG3 to REG6 (minimum training obligation) TTM19003