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HMRC internal manual

Tonnage Tax Manual

Chargeable gains: Outline

Capital losses

Capital losses brought forward into Tonnage Tax

A tonnage tax election does not affect the treatment of allowable losses that arose before entry into tonnage tax.  A tonnage tax company may therefore set off the full amount of any capital losses arising before it became a tonnage tax company against chargeable gains arising whilst it is a tonnage tax company.

Capital losses arising to tonnage tax company

As the normal CGT rules apply unless expressly amended by the tonnage tax rules, a tonnage tax company may also utilise or carry forward any capital losses arising during the regime, including:

  • Losses arising on the disposal of tonnage tax assets, calculated as described in TTM08200.
  • Losses arising on the disposal of non-tonnage tax assets, calculated using the normal CGT rules.


FA00/SCH22/PARA66 (losses brought forward) TTM17371
Pre-tonnage tax trading losses TTM07220