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HMRC internal manual

Tonnage Tax Manual

Ship leasing: Quantitative restrictions on allowances

Shared expenditure

If two or more persons share the cost of providing a ship that is subject to the restrictions on capital allowances described in TTM10400, then the restrictions are applied proportionately to each of those persons’ shares in the total cost.


A Ltd and B Ltd are two lessors who take an equal share in providing a qualifying ship costing £90 million to a tonnage tax company under a lease

A Ltd and B Ltd will each be entitled to:

*   * writing down allowances of 25 per cent a year on the first £20 million of their expenditure, and
    * writing down allowances of 10 per cent a year on the next £20 million of their expenditure, but
    * no allowances in respect of the remaining £5 million of their expenditure.


FA00/SCH22/PARA95 (3) (shared expenditure) TTM17551
Quantitative restrictions on allowances TTM10400