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HMRC internal manual

Tonnage Tax Manual

Schedule 22 Finance Act 2000: Part X the ring fence - capital allowances - ship leasing - Para 91C Tonnage Tax company to operate and manage a qualifying ship


(1) A lease of a qualifying ship provided, directly or indirectly, to a company within tonnage tax (“T”) falls within this paragraph if T is responsible—

(a) for the operation of the ship, including the appointment of the master and those members of the crew engaged in navigation, and

(b) for defraying all expenses in connection with the ship, or substantially all such expenses other than those directly incidental to a particular voyage or to the employment of the ship during any period for which the ship is leased by T to another person.

(2) For the purposes of this paragraph, T is “responsible” if—

(a) he is responsible as principal, or

(b) he appoints another person (“P”) to be responsible in his place and the condition in sub-paragraph (3) is met.

(3) The condition is that—

(a) P is not a person to whom the ship is leased by T and is not connected with such a person, or

(b) P is a company within tonnage tax.

(4) Any reference in this paragraph to a lease by T includes a reference to a contract of affreightment entered into by T that provides for the carriage of goods by the qualifying ship.

(5) Section 1122 of the Corporation Tax Act 2010 (connected persons) applies for the purposes of this paragraph.


Paras 91A-91F inserted by FA 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