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HMRC internal manual

Tonnage Tax Manual

Schedule 7 Finance Act 2005: PARA 13

The ring fence: capital allowances: exit: plant and machinery(1) Paragraph 85 is amended as follows.

(2) After sub-paragraph (1) insert-

“(1A) Sub-paragraph (1C) applies where the company leaves tonnage tax-

(a) on the expiry of a tonnage tax election, or

(b) on a tonnage tax election ceasing to be in force under paragraph 13(2A) (taking effect of withdrawal notice under paragraph 15A).
(1B) In any other case, sub-paragraph (2) applies.

(1C) Where this sub-paragraph applies, the amount of qualifying expenditure in respect of each asset used by the company for the purposes of its tonnage tax activities and held by the company when it leaves tonnage tax shall be taken to be-

(a) the market value of the asset at the time the company leaves tonnage tax, or

(b) if less, the amount of expenditure incurred on the provision of the asset that would have been qualifying expenditure if the company had not been subject to tonnage tax.”.
(3) In sub-paragraph (2) (amount of qualifying expenditure to be determined by reference to tax written down value of assets) at the beginning insert “Where this sub-paragraph applies”.