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HMRC internal manual

Tonnage Tax Manual

From
HM Revenue & Customs
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Schedule 22 Finance Act 2000: Part VIII chargeable gains and allowable losses on Tonnage Tax assets - Para 65 disposal of Tonnage Tax asset

FA00/SCH22/PARA65

(1) When an asset is disposed of that is or has been a tonnage tax asset-

(a) any gain or loss on the disposal is a chargeable gain or allowable loss only to the extent (if any) to which it is referable to periods during which the asset was not a tonnage tax asset, and

(b) any such chargeable gain or allowable loss on a disposal by a tonnage tax company is treated as arising otherwise than in the course of the company’s tonnage tax trade.

(2) For the purposes of sub-paragraph (1) the amount of the gain or loss on a disposal means what would be the amount of the chargeable gain or allowable loss apart from this paragraph.

(3) The proportion of that gain or loss referable to periods during which the asset was not a tonnage tax asset is given by:

(P - PTTA) ÷ P

where:

P is the total length of the period since the asset was created or, if later, the last third-party disposal, and

PTTA is the length of the period (or the aggregate length of the periods) since-

(a) the asset was created, or

(b) if later, the last third-party disposal,

during which the asset was a tonnage tax asset.

(4) In sub-paragraph (3) a “third-party disposal” means a disposal (or deemed disposal) that is not treated as one on which neither a gain nor a loss accrues to the person making the disposal.

References

Time apportionment TTM08200