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HMRC internal manual

Tonnage Tax Manual

From
HM Revenue & Customs
Updated
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Chargeable gains: Roll-over relief

Depreciating asset becomes a tonnage tax asset

Normal rules continue to apply if the new asset is a depreciating asset

Where the new asset is a depreciating asset, of which a ship is a good example, the roll-over relief will have been given by holding over the gain, rather than deducting it from the cost of the new asset. In such a case, the full amount of the gain will eventually be brought into account for tax purposes even if the new asset subsequently becomes a tonnage tax asset.

The normal roll over provisions S154 TCGA 1992 will therefore continue to apply if the new asset is a depreciating asset. (see CG60370).

References

 

TCGA92/S154 (new assets which are depreciating assets) CG60370