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