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

FA00/SCH22/PARA16 (qualifying companies and groups)

TTM17086

Meaning of ‘operating a ship’

TTM03100

Definition of a ‘qualifying ship’

TTM03500

The meaning of ‘strategically and commercially managed in the UK’

TTM03800