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HMRC internal manual

Tonnage Tax Manual

HM Revenue & Customs
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Tonnage tax groups: Group arrangements

Matters covered

A group arrangement will normally cover the following matters:

  • Dealing with the HMRC on behalf of group companies in respect of non-statutory business clearances.
  • Dealing with the HMRC on behalf of group companies in respect of the tonnage tax election and renewal elections.
  • Making notifications on behalf of group companies as to whether or not the 75 per cent limit on chartering-in (set out in FA00/SCH22/PARA37) has been exceeded and making any appeal under PARA43 (against an exclusion from tonnage tax notice).
  • Preparing and negotiating with the HMRC calculations required under PARA62 (finance costs).
  • Dealing with the HMRC on matters arising under PARA26 (4) (dominant party on a merger) and making an appeal under PARA126 (5) (against HMRC determination).
  • Making notifications under PARA129 (duty to notify HMRC of group changes).
  • The provision of any other information in relation to the tonnage tax regime, which it would be expedient to be provided on a group-wide basis.

It will not affect the requirement that an election be made jointly by all qualifying companies in a tonnage tax group, or any liability of a particular company under any provision of the Taxes Acts.


FA00/SCH22/PARA120 (arrangements for dealing with group matters) TTM17676
Group arrangements TTM12210
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