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HMRC internal manual

Tonnage Tax Manual

HM Revenue & Customs
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Tonnage tax groups: Control

Meaning of ‘settlement’ and ‘settlor’

‘Settlement’ includes any disposition, trust, covenant, agreement, arrangement or transfer of assets.

‘Settlor’ in relation to a settlement, means any person by whom the settlement was made.

See FA00/SCH22/PARA144 (3) and ITTOIA05/S620 (1).

A person shall be deemed to have made a settlement if:

  • he has made or entered into the settlement directly or indirectly, or
  • he has provided or undertaken to provide funds directly or indirectly for the purposes of the settlement, or
  • he has made with any other person a reciprocal arrangement for that other person to make or enter into the settlement.


FA00/SCH22/PARA144(3) (meaning of ‘settlement’ and ‘settlor’) TTM17796
Control by an individual TTM12020