TTM03001 - Qualifying Companies & Ships: Qualifying company
Meaning
A company is a ‘qualifying company’ for tonnage tax purposes if-
- it is within the charge to corporation tax,
- it operates (see TTM03100) one or more qualifying ships (see TTM03500), and
- those ships are strategically and commercially managed in the United Kingdom (see TTM03800)
Exception: Temporarily ceasing to operate qualifying ships
The only exception to this definition is that a company that temporarily ceases to operate qualifying ships may continue to be a qualifying company if certain conditions are met (see TTM03050).
Non-residents
A non-resident company trading in the UK through a branch or agency is within the charge to corporation tax, and can be a qualifying company if the other conditions are satisfied. HMRC considers it unlikely that a branch or agency would be able to satisfy the strategic management test (see TTM 03800 et seq).
References
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FA00/SCH22/PARA16 (qualifying companies and groups) |
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Meaning of ‘operating a ship’ |
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Definition of a ‘qualifying ship’ |
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The meaning of ‘strategically and commercially managed in the UK’ |
