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HMRC internal manual

Tonnage Tax Manual

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HM Revenue & Customs
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Ship leasing: Quantitative restrictions on allowances

Restrictions cease to apply: Introduction

The restrictions on capital allowances available to lessors of ships only apply where the ship is a qualifying ship provided for use by a tonnage tax company.

If this ceases to be the case, perhaps because the lessee’s tonnage tax election expires, or because the ship is converted to non-qualifying use, then the restrictions cease to apply.

Expenditure on the ship in question should be moved from the lessor’s 18 per cent and 8 per cent tonnage tax pools and moved back into the normal capital allowances pool.

See TTM10510 for details of how the reallocation of expenditure is to be done

References

FA00/SCH22/PARA99 (change of circumstances taking out case) TTM17571
   
Restrictions cease to apply: Procedure TTM10510
Restrictions cease to apply: Example TTM10520