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HMRC internal manual

Tonnage Tax Manual

HM Revenue & Customs
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Relevant shipping profits: Qualifying secondary activities

FA00/SCH22/PARA47 allows HMRC to provide by regulation for the:

  • description of activities that are qualifying secondary activities, and
  • the permitted level of such activity within tonnage tax.

Definition of ‘qualifying secondary activities’’

Secondary qualifying activities are defined in SI00/2303/REG 3.  Broadly, the activities included in this category are those ship-related activities customarily provided, or desirable, as part of the qualifying shipping activities, whether for the company or other group members. For instance, providing food for short sea ferry passengers is not integral and necessary to their transport and is therefore not core.  However, it is a wholly qualifying secondary activity.

They must have a substantial connection with:

  • the company’s core qualifying activities, or
  • the core qualifying activities of another qualifying company in the same tonnage tax group (But see TTM06130 regarding services provided to associates).

They fall into two categories:

  • activities which qualify without restriction (see TTM06110)
  • activities which only qualify up to a certain level (see TTM06120).


FA00/SCH22/PARA47 (provision to make regulations) TTM17276
SI00/2303/REG3 (qualifying secondary activities) TTM18003
SI00/2303/REG2(3) (ship operated by another qualifying company) TTM18002