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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 91E anti-avoidance


Paragraph 91A(2) does not have effect in the case of the lease if the main purpose, or one of the main purposes—

(a) of the leasing of the ship,

(b) of a series of transactions of which the leasing of the ship is one, or

(c) of any of the transactions in such a series,

was to obtain a writing down allowance determined without regard to any of paragraphs 90, 92 and 94 to 102 in respect of expenditure incurred by any person on the provision of the ship.*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