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HMRC internal manual

Tonnage Tax Manual

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Schedule 22 Finance Act 2000: Part IX the ring fence - capital allowances - Para 69 entry - plant and machinery - assets to be used wholly for Tonnage Tax trade

FA00/SCH22/PARA69

(1) On a company’s entry into tonnage tax any unrelieved qualifying expenditure attributable to plant or machinery that is to be used wholly for the purposes of the company’s tonnage tax trade is taken to a single pool (the company’s “tonnage tax pool”).

(2) In this paragraph “unrelieved qualifying expenditure” has the same meaning as in Chapter 5 of Part 2 of the Capital Allowances Act 2001.

(3) The amount of unrelieved qualifying expenditure attributable to plant or machinery in a class pool, or the main pool, is the proportion of the whole given by:

AV ÷PV

where:

AV is the aggregate market value of the assets concerned immediately before entry into tonnage tax, and

PV is the aggregate market value at that time of all the assets in the pool.

(4) References in this paragraph to unrelieved qualifying expenditure include qualifying expenditure to the extent to which it is unrelieved by virtue of notice having been given under section 130 of the Capital Allowances Act 2001 (notice postponing first-year or writing-down allowance).

No allowance may be claimed in respect of any such expenditure taken to the company’s tonnage tax pool.

History

Amended by Schedule 2 CAA 2001. Up to 31st March 2001 subparagraphs 2 and 4 read:

(2) For the purposes of this paragraph “unrelieved qualifying expenditure” means the balance that would otherwise have been carried forward under Part II of the Capital Allowances Act 1990.

(4) References in this paragraph to unrelieved qualifying expenditure include qualifying expenditure to the extent to which it is unrelieved by virtue of notice having been given under-

(a) section 30(1) of the Capital Allowances Act 1990 (postponement or reduction of first year allowances), or

(b) section 31(3) of that Act (postponement of writing-down allowance in respect of expenditure in single ship pool).

No allowance may be claimed in respect of any such expenditure taken to the company’s tonnage tax pool.

References

Tonnage Tax pool (frozen pool) TTM09010