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HMRC internal manual

Tonnage Tax Manual

Schedule 7 Finance Act 2005: Para 12

The ring fence: capital allowances: general: introduction(1) Paragraph 68 is amended as follows.

(2) In sub-paragraph (2) (description of general scheme of Part 9 of Schedule 22) for paragraph (c) substitute-

“(c) on leaving tonnage tax-

(i) a company is treated as having incurred qualifying expenditure on its tonnage tax plant and machinery assets of an amount equal to the lower of cost and market value, where it leaves tonnage tax on expiry of an election or on the taking effect of a withdrawal notice, but  
(ii) otherwise, a company is put broadly in the position it would have been in if it had never been subject to tonnage tax.".