TTM08020 - Chargeable gains: Outline

Capital losses

Capital losses brought forward into tonnage tax

A tonnage tax election does not affect the treatment of allowable losses that arose before entry into tonnage tax.  A tonnage tax company may therefore set off the full amount of any capital losses arising before it became a tonnage tax company against chargeable gains arising whilst it is a tonnage tax company.

Capital losses arising to tonnage tax company

As the normal chargeable gains rules apply unless expressly amended by the tonnage tax rules, a tonnage tax company may also utilise or carry forward any capital losses arising during the regime, including:

  • Losses arising on the disposal of tonnage tax assets, calculated as described in TTM08200.
  • Losses arising on the disposal of non-tonnage tax assets, calculated using the normal chargeable gains rules.

References

FA00/SCH22/PARA66 (losses brought forward)

TTM17371

Pre-tonnage tax trading losses

TTM07220