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HMRC internal manual

Tonnage Tax Manual

HM Revenue & Customs
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Chargeable Gains: Roll-over relief


The normal capital gains rules

Guidance on the normal rules for roll-over relief is at CG60250 onwards. Broadly speaking, the relief may be claimed where the proceeds from the disposal of qualifying assets are applied, within specified time limits, in acquiring new qualifying assets. The relief takes the form of a reduction in consideration for disposal of the old asset and, where the new asset is non-depreciating:

  • a reduction in the cost of acquisition of the new asset,

or, where the ‘new asset’ is depreciating:

  • a holding over of the capital gains charge until the earlier of:

    • disposal of the ‘new asset’, or
    • ceasing to use the ‘new asset’ for trade, or
    • 10 years from the acquisition of the ‘new asset’.

Effect of tonnage tax regime on roll-overs and hold-overs

A claim to roll-over relief may not be made to the extent that the ‘new asset’ is a tonnage tax asset, (see TTM08310),

A pre-tonnage tax gain rolled over under S152/3 TCGA 1992 against non-depreciating asset, which becomes a tonnage tax asset, is crystallised but held over, (see TTM08320).

A pre-tonnage tax gain held over under S154 TCGA 1992 against depreciating asset, which becomes tonnage tax asset, remains unaffected by entry into tonnage tax, (see TTM08330).


FA00/SCH22/PARA67 (roll-over relief for business assets) TTM17376
TCGA92/S152 (roll-over relief) CG60250
TCGA92/S154 (new assets which are depreciating assets) CG60370