Commentary

D7.1004A Qualifying conditions—strategic and commercial management

Corporate tax
Corporate tax | Commentary

D7.1004A Qualifying conditions—strategic and commercial management

Corporate tax | Commentary

D7.1004A Qualifying conditions—strategic and commercial management

Elements of each 'leg' of the strategic and commercial management test must be demonstrated. In order to be a qualifying company, the company's qualifying ships must be strategically and commercially managed in the UK and therefore these tests must be satisfied by each company in a tonnage tax group.

HMRC in consideration of strategic and commercial management, will look at all elements of management activity relevant to the ships including1:

  1.  

    (a)     strategic functions for the shipping business such as:

    1.  

      (1)     the location of headquarters and senior management staff

    2.  

      (2)     decision making of the company board

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