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HMRC internal manual

Tonnage Tax Manual

Partnerships: Outline

Elections into Tonnage Tax

As set out in TTM02001, a tonnage tax election has to be made on a group-wide basis. All qualifying activities carried on by a company, or group of companies, must be brought within the tonnage tax ring-fence – including any carried on through a corporate partnership.

If a company or group only carries on qualifying activities through a corporate partnership (or, indeed, through more than one corporate partnership), it may still elect into tonnage tax.


FA00/SCH22/PARA1(2) (all companies in a group must join election) TTM17001
FA00/SCH22/PARA7 onwards (elections) TTM17031
SI00/2303/REG9 (partner as qualifying company) TTM18009