HMRC internal manual

Tonnage Tax Manual

Tonnage tax groups: Group arrangements

You should check the other guidance available on GOV.UK from HMRC as Brexit updates to those pages are being prioritised before manuals.

There are advantages for both the taxpayer and HMRC if a tonnage tax group operates under a group arrangement under FA00/SCH22/PARA120).  A group arrangement will enable a nominated company to act as a representative of the group.  This will reduce the need for administrative correspondence between the HMRC and each individual company in the group, and make some aspects of the legislation much simpler to implement, e.g. the provisions of FA00/SCH22/PARA37 (75 per cent limit) and PARA62 (finance costs).


FA00/SCH22/PARA120 (arrangements for dealing with group matters) TTM17676
Matters covered by group arrangement TTM12220
Arrangements for dealing with group matters TTM12230
Inspector’s agreement to group arrangement TTM12240
Changes to group arrangement - membership TTM12250
Changes to group arrangement – details covered TTM12260