Chargeable gains: Time-apportionment
When an asset is disposed of, and that asset is (or has been) a tonnage tax asset, only the gain or loss referable to the time when it was not a tonnage tax asset is brought into account for tax purposes as a chargeable gain or allowable loss.
Computation of gain or loss
The gain or loss to be brought into account for tax purposes is calculated:
- by time apportioning the total gain or loss arising (calculated by reference to the normal CGT rules)
- by reference to the time that the asset was used outside tonnage tax
- as a proportion of the total time that the asset was owned by the company.
See TTM08210 for details of how the chargeable gain or allowable loss is to becalculated.
Where the asset has been transferred around a group in such circumstances that each disposal fell to be dealt with under the no gain/no loss rules in TCGA92/S171(1) (see CG45300 onwards), the time apportionment is made by reference to the total time that the asset was owned by the group.
|FA00/SCH22/PARA65 (disposal of tonnage tax asset)||TTM17366|