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HMRC internal manual

Tonnage Tax Manual

Ship leasing: Defeased leasing

Pre-delivery guarantees

When looking at the extent of removal of non-compliance risk from the lessor, any pre-delivery guarantees, whereby the lessor obtains guarantees in respect of interim finance during the construction stage, may be left out of account.

HMRC accepts that such guarantees are not part of the leasing structure once the ship has been delivered and the lease is in place.