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HMRC internal manual

Tonnage Tax Manual

Partnerships: Capital allowances

On exit from tonnage tax: Variations in share of partnership property

TTM13420 and TTM13440describe the way that the other partners’ future entitlement to capital allowances may be affected when one of the partners leaves tonnage tax.

In both cases the adjustment required is based upon the tonnage tax companies’ share in partnership property (amount ‘A’ in the formulae).

If there has been a variation in that company’s share in partnership property in the six years preceding the point at which adjustment is made, then the figure to be used is the average of the company’s share over that period instead.

If the company has been a corporate partner, or has been a tonnage tax company, for less than six years, then the figure to be used is the average of the company’s share over the period from the later of these two events to the time when the adjustment is needed.

References

SI00/2303/REG8 (8) (variation in share of partnership property) TTM18008
   
Compensatory payments between partners TTM13450