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HMRC internal manual

Tonnage Tax Manual

Corporate partnerships: Outline

Companies that are members of a partnership may bring qualifying activities carried on through that partnership into tonnage tax, even if some or all other partners are outside the regime.  The detailed rules are contained in FA00/SCH22/RARA130 to PARA136 and in SI00/2303/REG8 onwards.

These rules cover, amongst other things:

i)  the computation of tonnage tax and non-tonnage tax profits,

ii)  the application of the 75 per cent chartering-in limit,

iii)  the computation of chargeable gains, and

iv)  the calculation of capital allowances following a partner’s exit from tonnage tax ,

and will apply equally to those partnerships that have legal personality (as in Scotland), as they do to partnerships that do not.

Broadly speaking, the effect of these provisions will enable a partner, which is a tonnage tax company to calculate the partnership profit along tonnage tax lines.  Partners, who are not within tonnage tax, will calculate their share of partnership profit by reference to normal UK corporation tax principles.  Thus, there may be different parallel computations of the profits of one partnership, e.g. one on tonnage tax lines and one on normal corporation tax lines. The Tonnage Tax Technical Adviser will advise on points of concern or difficulty.


Outline of tonnage tax rules for partnerships TTM13001
FA00/SCH22/PARA131 to PARA136 (application of provision to partnerships)  
SI00/2303/REG8 to REG13 (application of provision to partnerships)