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HMRC internal manual

Tonnage Tax Manual

HM Revenue & Customs
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Tonnage tax groups: Control

Exclusion from control

An individual shall not be treated as controlling a company by the attribution of ‘associates’ if he does not have any significant influence over the affairs of the company in question (FA00/SCH22/PARA117 (2)).

Whether ‘significant influence’ exists will be interpreted according to the facts of each particular case. It will generally be presumed that where there is a close family relationship, such as husband and wife or parent and minor child, then significant influence will exist. An example of where significant influence may not exist is where there has been a long-term demonstrable family rift and the controlling parties have no contact with each other.


FA00/SCH22/PARA118 (meaning of ‘control’) TTM17666
Meaning of ‘control’ TTM12070
Attribution of powers to achieve control TTM12080
Company not to be treated as member of more than one group TTM12100