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HMRC internal manual

Tonnage Tax Manual

From
HM Revenue & Customs
Updated
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Partnerships: Operation of ships

No double counting

If a tonnage tax company is a member of a partnership and provides a ship to the partnership for its use (by means of a formal charter or otherwise), both the tonnage tax company and the partnership are treated as operating the ship (see TTM13100).

However, the ship should only be counted in one computation of tonnage tax profits – that of the partnership.

References

SI00/2303/REG10 (3) (rules for counting tonnage tax profit) TTM18010
   
Operation of ships TTM13100
Bareboat charter-out TTM13120