Beta This part of GOV.UK is being rebuilt – find out what this means

HMRC internal manual

Tonnage Tax Manual

From
HM Revenue & Customs
Updated
, see all updates

Relevant shipping profits: Core qualifying activities

Definition of ‘core qualifying activities’

FA00/SCH22/PARA46 provides that a company’s ‘core qualifying activities’ consist of

  • activities in operating qualifying ships, and
  • other ship-related activities that are a necessary and integral part of the business of operating those qualifying ships.

Operating ships

Operation of the ship is defined by FA00/SCH22/PARA18 in terms of ownership and charter, but to be qualifying the ship must, under PARA19 (1), be used for

  • transport of passengers or cargo by sea,
  • towage salvage or other marine assistance carried out at sea, or
  • transport in connection with other  services of a kind necessarily provided at sea.

‘Necessary and integral’

Activities are a ‘necessary and integral part of the business’ if they are essential to enable the ship operation to take place.  Thus the definition will encompass:

  • ship management operations, such as purchasing fuel and hiring crew, and
  • commercial management operations such as booking cargo.

Activities not included

The definition of ‘core qualifying activities’ will not include every ship-related activity that a company may carry on.  In particular, the definition does not cover:

  • activities that are merely customary or desirable
  • activities carried out on behalf of other companies in the same tonnage tax group

Although they are not ‘core qualifying activities’, such activities may be ‘qualifying secondary activities’ (see TTM06100), or possibly ‘qualifying incidental activities’ (see TTM06200)

References

FA00/SCH22/PARA46 (core qualifying activities) TTM17271
   
Examples of core qualifying activities TTM06060
Liner conferences and pooling TTM15210