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HMRC internal manual

Tonnage Tax Manual

From
HM Revenue & Customs
Updated
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Partnerships: Chargeable gains

As described in TTM08001, when an asset is disposed of and that asset is (or has been) a tonnage tax asset, any gain or loss referable to the time when it was a tonnage tax asset is disregarded for the purposes of corporation tax on chargeable gains.

The normal definition of a tonnage tax asset is that it is a capital asset used wholly and exclusively for the tonnage tax activities of a tonnage tax company.

This definition is extended to include an asset used wholly and exclusively for the purposes of the tonnage tax activities of a corporate partnership, if that asset were owned at that time by a tonnage tax company that is a member of that partnership.

Assets used by the partnership in its shipping business, but owned by partners outside the tonnage tax regime, are not tonnage tax assets.

References

SI00/2303/REG12 (chargeable gains: use of assets by partnerships) TTM18012