TTM13150 - Partnerships: Operation of ships

75% limit on chartering-in to partner: Example

Beau Ltd is a singleton tonnage tax company with, for the accounting period year ended 31 December 2006:

  • a 50% share in a corporate partnership, Beau-Geste Ferries,
  • a 25% share in another corporate partnership, Beau-Regarde Ferries, and
  • two 3,000-ton vessels (time-chartered-in), which it operates on its own account.

Beau-Geste Ferries operates four 5,000-ton vessels, of which:

  • three are bare boat chartered-in, and
  • one held on a time charter for the whole of the 12-month accounting period.

Beau-Regarde Ferries operates two vessels:

  • one 8,000-ton vessel bareboat chartered-in for the whole of the 12-month accounting period, and
  • one 4,000-ton vessel time chartered-in for the last 6 months of the accounting period.

Beau Ltd’s percentage of chartered-in tonnage is worked out as follows:


 

 

Beau-Geste Ferries

Beau-Regarde Ferries

Step One

Aggregate Tonnage (in ton-days)

4 x 5,000 x 365=

7,300,000

(8,000 x 365) +

(4,000 x 184) =

3,656,000

Step Two

Tonnage chartered in (ton-days)

1 x 5,000 x 365 =

1,825,000

1 x 4,000 x 184 =

736,000

 

% chartered in

25%

20%

Step Three

Share in partnership property

50% x 7,300,000 =

3,650,000 ton-days

25% x 3,656,000 =

914,000 ton-days

 

Allocation of chartered-in tonnage in Step 2

25% x 3,650,000 =

912,500 ton days

20% x 914,000 =

182,800 ton days

Step Four

Total share of tonnage operated

3,650,000 + 914,000 = 4,564,000 ton days

 

Share of tonnage chartered-in

912,500 + 182,800 = 1,095,300 ton days

Step Five

Own tonnage

2 x 3,000 x 365 =

2,190,000

 

Total own and partnership tonnage

2,190,000 + 4,564,000  = 6,754,000 ton days

 

Own and partnership tonnage chartered- in

2,190,000 + 1,095,300 = 3,285,300 ton days

Step Six

Aggregate percentage chartered- in

48.64%

 

Apply 75% test to Step Six result

Beau Ltd is below the 75% limit for this accounting period

References

75% limit on chartering-in to partner

TTM13140