TTM06050 - Relevant shipping profits: Core qualifying activities

Definition of ‘core qualifying activities�

FA00/SCH22/PARA46 provides that a company’s ‘core qualifying activities� 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  services of a kind necessarily provided at sea.

‘Necessary and integral�

Activities are a ‘necessary and integral part of the business� if they are essential to enable the ship operation to take place.  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 ‘core qualifying activities� will not include every ship-related activity that a company may carry on.  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 ‘core qualifying activities�, such activities may be ‘qualifying secondary activities�, see TTM06100, or possibly ‘qualifying incidental activities�, see TTM06200.

References

FA00/SCH22/PARA46 (core qualifying activities) TTM17271
Examples of core qualifying activities TTM06060
Liner conferences and pooling TTM15210