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HMRC internal manual

Tonnage Tax Manual

From
HM Revenue & Customs
Updated
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Capital allowances: Balancing charges (P&M)

Surrender of unrelieved qualifying expenditure

If a disposal event takes place, and the disposal value exceeds the amount remaining in the company’s own tonnage tax pool, the company may still be able to avoid a balancing charge by utilising expenditure from a fellow group company’s tonnage tax pool.

In such a case one member of a tonnage tax group may surrender all or part of the expenditure remaining in its tonnage tax pool to another company in the same group.

In order for such a surrender to take place, the two companies must have been members of the same group for at least a year at the time of the disposal potentially giving rise to the balancing charge.

References

FA00/SCH22/PARA81 (surrender of unrelieved qualifying expenditure) TTM17441