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HMRC internal manual

Tonnage Tax Manual

Ship leasing: Defeased leasing

What to do with queries

If HMRC tax specialists are asked whether FA00/SCH22/PARA90 will apply to deny capital allowances on the proposed finance lease of a qualifying ship to a tonnage tax company, they should obtain the full facts relating to the transaction, and submit the case to the Tonnage Tax Technical Adviser.

The Tonnage Tax Technical Adviser will liaise with the Counter Avoidance Directorate as necessary.


Contact points TTM01120