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HMRC internal manual

Tonnage Tax Manual

HM Revenue & Customs
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Schedule 22 Finance Act 2000: Part VII the ring fence - Para 53 Tonnage Tax trade


(1) The tonnage tax activities of a tonnage tax company are treated for corporation tax purposes as a separate trade (the company’s “tonnage tax trade”) distinct from all other activities carried on by the company.

(2) Sub-paragraph (1) shall not be read as requiring a company to be treated-

(a) as setting up and commencing a new trade on entry into tonnage tax, or

(b) as permanently ceasing to carry on a trade on leaving tonnage tax.


Tonnage Tax trade TTM07020