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HMRC internal manual

Tonnage Tax Manual

The ring fence: Outline: Tonnage tax trade

A company’s tonnage tax activities are treated as a separate trade from any other business it carries on. This is so that all income and expenses relating to a company’s tonnage tax activities will dealt with inside the tonnage tax ring fence whilst any other income and expenditure remains subject to normal corporation tax rules outside the ring fence.

However, the fact that a company’s tonnage tax activities are a separate trade does not mean that the company should be treated as starting up a new trade when it enters Tonnage Tax, or as ceasing to carry on that trade when it leaves the regime.


(This ensures that the commencement and cessation provisions; for example, as regards capital allowance computations do not apply.)



FA00/SCH22/PARA53 (tonnage tax trade) TTM17306