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HMRC internal manual

Tonnage Tax Manual

Tonnage tax groups: Control

Meaning of ‘control’

‘Control’ of a company means, per FA00/SCH22/PARA118, the power of a person to secure by means of:

  • a shareholding, or
  • voting power, directly or indirectly through other companies, or
  • any powers conferred by articles of association or other document regulated that or any other company,

so that the affairs of the company are conducted in accordance with his wishes.


FA00/SCH22/PARA118 (meaning of ‘control’) TTM17666
Attribution of powers to achieve control TTM12080
Exclusion from control TTM12090
Company not to be treated as member of more than one group TTM12100