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