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HMRC internal manual

Tonnage Tax Manual

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HM Revenue & Customs
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Tonnage Tax Regulations 2000: Regulation 10

Corporate partners - Rules for calculating the tonnage tax profits and relevant shipping profits of a corporate partner

SI00/2303/REG10(1) Paragraph (2) applies to any corporate partner which is a tonnage tax company (but only in relation to the share of profits or losses which such a partner derives from the activities carried on in the partnership concerned).

(2) Section 114 of the Taxes Act shall apply to the profits and losses of the partnership as if the partnership were a tonnage tax company, for the purpose of calculating -

(a) the tonnage tax profits, and
 
(b) the relevant shipping profits (or such of the corresponding losses as fall within paragraph 3(2) of Schedule 22),
of any corporate partner to whom this paragraph applies (but not the share of profits or losses of any other partner).

(3) Where a ship falls to be counted as operated by a partnership in a calculation under paragraph (2)(a) carried out in relation to a corporate partner, it shall not be counted again in any computation of the tonnage tax profits of that corporate partner, and the same provision shall apply as between a calculation under paragraph (2)(b) and the relevant shipping profits (or relevant corresponding losses) of a corporate partner.

References

No double counting in partnership operation of ships TTM13110
   
Bareboat charter-out TTM13120