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HMRC internal manual

Tonnage Tax Manual

Tonnage tax groups: Control

Meaning of ‘group’

FA00/SCH22/PARA116 defines a ‘group’ for tonnage tax purposes as:

  • all the companies controlled by an individual, or
  • where a company, that is not controlled by another person, controls one or more other companies, that company and all the companies controlled by it.

A ‘member of a group’ is one of those companies.

A group for tonnage tax purposes therefore includes overseas companies, as well as UK ones. For most tonnage tax purposes, this is only relevant for bringing two UK companies under common overseas control into the same tonnage tax group.


FA00/SCH22/PARA116 TTM17086
Control by an individual TTM12020