Revenue Note for Guidance
This section makes provision for relief in relation to chargeable gains which arise on the disposal of assets which were used for a company’s tonnage tax trade.
(1) Assets used for a company’s tonnage tax trade but which are also used for other purposes are treated as separate assets.
(2) An apportionment is to be made on a just and reasonable basis of any gain/loss arising on a disposal of an asset treated in accordance with this section as separate assets.
(3) An exemption from tax is provided for any gain arising on an asset for the period for which the asset was used for the purposes of the company’s tonnage tax trade. Apportionment of the gain/loss between time in tonnage and time outside of tonnage tax is to be made on a time basis.
(4) Capital losses referable to periods outside of tonnage tax are available for set off against any capital gains arising on a tonnage tax asset which is referable to periods spent outside of tonnage tax.
Relevant Date: Finance Act 2021