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HMRC internal manual

Tonnage Tax Manual

HM Revenue & Customs
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Chargeable gains: Time apportionment

Disposals by non-tonnage tax companies

The time apportionment rules described in TTM08200 will also apply to a disposal by a non-tonnage tax company of an asset, which has previously been a tonnage tax asset within the same group for capital gains tax purposes.

For example:

  • A company which has used the asset as a tonnage tax asset may have left the regime before it disposed of the asset in question
  • A non-tonnage tax company making the disposal may have acquired the asset on a no gain/no loss transfer from a fellow group member, which had used it as a tonnage tax asset.