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HMRC internal manual

Tonnage Tax Manual

Partnerships: The ring fence


As described in TTM10001 onwards, there are special rules to restrict the capital allowances available to lessors in respect of expenditure on qualifying ships provided to tonnage tax companies.

These restrictions also apply to cases where the leased ship is provided to a corporate partnership where one or more of the members is a tonnage tax company.


SI00/2303/REG9 (4) (supplementary provision relating to leases) TTM18009