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HMRC internal manual

Tonnage Tax Manual

The 75% limit on charters-in: If limit exceeded

Exclusion procedure: Appeals

If HMRC excludes a company or group from tonnage tax because it has exceeded the 75% limit, the company or group may appeal against the exclusion notice within 30 days of the date of issue of the notice.

Where a group is appealing, only one appeal may be brought, but it may be brought jointly by two or more members of the group.

A company that disagrees with HMRC’s decision to exclude, can appeal to have the decision reviewed internally, or appeal to have the decision heard by the First Tier Tribunal. If the company seeks an internal review, and does not agree with the decision of that review, it can then appeal to the First Tier Tribunal.

The appeal should be delivered to the officer who issued the notice.

The First Tier Tribunal has jurisdiction over such appeals (paragraph 43(1)).


Consideration of exclusion by HMRC TTM05310
Action by officer where limit exceeded TTM05320
Exclusion procedure TTM05330