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HMRC internal manual

Tonnage Tax Manual

Capital Allowances: Entry into tonnage tax (P&M)

Unrelieved qualifying expenditure

For the purpose of calculating the amount to be taken to the tonnage tax (frozen) pool (see TTM09010), ‘unrelieved qualifying expenditure’ means:

  • the balance that would otherwise have been carried forward under CAA01/PART2 – i.e. the written down value immediately before the company’s entry into tonnage tax, after effect has been given to capital allowances claims for the final pre-tonnage tax period


  • any balance of qualifying expenditure which remains unrelieved by virtue of notice having been given under CAA01/S130 i.e. any outstanding ‘free depreciation’, (see CA25200 onwards).


FA00/SCH22/PARA69(2) & (4) (tonnage tax pool) TTM17386
Tonnage tax pool TTM09010