Tonnage tax – Specialist Ships
HMRC have recently announced a change in their view on the tonnage tax treatment of certain ships. This change is relevant to shipping companies that have elected to have corporation tax profits deriving from maritime transport activities of qualifying ships calculated under the rules of Tonnage Tax.
HMRC now considers that its initial interpretation of legislation in FA 2000 that profits and losses from the operation of specialist ships should be apportioned between a transportation and a services element is incorrect.
HRMC have now accepted that where a vessel qualifies for Tonnage Tax under paragraph 19(1)(d) Schedule 22 Finance Act 2000 no apportionment is required and all profits arising from both transportation and services fall within the Tonnage Tax ring-fence.
HMRC have also announced that they will settle any open cases or in-date amended returns involving specialist ships on this basis. Revised guidance will be published later this year.