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HMRC internal manual

Tonnage Tax Manual

HM Revenue & Customs
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Schedule 22 Finance Act 2000: Part X the ring fence - capital allowances - ship leasing - Para 91B lease to Tonnage Tax company or group


(1) A lease falls within this paragraph if—

(a) it is a lease of a qualifying ship provided directly to a company within tonnage tax, or

(b) it is a lease of a qualifying ship provided indirectly to a company within tonnage tax (“T”) and sub-paragraph (2) applies.

(2) This sub-paragraph applies where—

(a) the owner of the qualifying ship provides it directly to a company (“C”) under a lease,

(b) C provides the qualifying ship directly to T under a lease, and

(c) C and T are in the same group *.1


*1 Paras 91A-91F inserted byFA 2006 s 81, Sch 9 paras 8, 10 with effect in accordance with the commencement provisions in FA 2006 Sch 8 para 15.


Long funding leases TTM10215