TTM10490 - Ship Leasing: Quantitative restrictions on allowances

Restrictions begin to apply: Example

Partex Ltd is a leasing company claiming capital allowances at 25% on its machinery and plant pool for the AP year ending 31 December 2005. The pool includes several ships, which are either non-qualifying or leased to non-tonnage tax companies.

One of the leased ships in that pool (which originally cost £50m) becomes a qualifying ship within Tonnage Tax on 30 June 2005. As at 1 January 2005 the unrelieved qualifying expenditure in the machinery and plant general pool is £8 million.

The ‘tax written value’ of the ship is

• £4 million as at 1 January 2005 (Amount A)
• £3.5 million as at 30 June 2005 (Amount B)

The capital allowance consequences for the accounting period ended 31 December 2005 are as follows:

• The normal capital allowances pool

• The amount treated as a disposal from the normal pool is Amount A: £4 million
• The writing down allowance on the remainder of the pool is (£8 million - £4 million) x 25% = £1,000,000

• The temporary pool

• The amount taken to the temporary pool is Amount A (£4 million) and the disposal value to be taken into account upon its closure on 30 June 2005 is Amount B: £3.5 million
• The balancing allowance upon closure of the temporary pool is £4 million - £3.5 million = £500,000

• The tonnage tax class pools

• This disposal value of £3.5 is allocated 40/50 to the 25% pool and 10/50 to the 10% pool (in proportion to the original cost of the vessel), ie £2.8 million and £0.7 million respectively.
• Writing-down allowances from the 25% pool are (£2.8 million x 6/12 x 25%) = £350,000
• Writing-down Allowances from the 10% pool are (£0.7 million x 6/12 x 10%) = £35,000

The total capital allowances available to the lessor from this period are writing-down allowances from the normal pool, the 25% pool and the 10% pool of £1,000,000, £350,000 and £35,000 respectively, plus the balancing allowances from the temporary pool of £500,000, totalling £1,885,000.

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