TTM06050 - Relevant shipping profits: Core qualifying activities
Definition of 鈥榗ore qualifying activities鈥�
FA00/SCH22/PARA46 provides that a company鈥檚 鈥榗ore qualifying activities鈥� consist of:
- activities in operating qualifying ships, and
- other ship-related activities that are a necessary and integral part of the business of operating those qualifying ships.
Operating ships
Operation of the ship is defined by FA00/SCH22/PARA18 in terms of ownership and charter of the vessel, but to be qualifying the ship must, under PARA19 (1), be used for:
- transport of passengers or cargo by sea,
- towage salvage or other marine assistance carried out at sea, or
- transport in connection with other 聽services of a kind necessarily provided at sea.
鈥楴ecessary and integral鈥�
Activities are a 鈥榥ecessary and integral part of the business鈥� if they are essential to enable the ship operation to take place.聽 Thus the definition will encompass:
- ship management operations, such as purchasing fuel and hiring crew, and
- commercial management operations such as booking cargo.
Activities not included
The definition of 鈥榗ore qualifying activities鈥� will not include every ship-related activity that a company may carry on.聽 In particular, the definition does not cover:
- activities that are merely customary or desirable, or
- activities carried out on behalf of other companies in the same tonnage tax group.
Although they are not 鈥榗ore qualifying activities鈥�, such activities may be 鈥榪ualifying secondary activities鈥�, see TTM06100, or possibly 鈥榪ualifying incidental activities鈥�, see TTM06200.
References
FA00/SCH22/PARA46 (core qualifying activities) | TTM17271 |
Examples of core qualifying activities | TTM06060 |
Liner conferences and pooling | TTM15210 |