TTM10410 - Ship leasing: Quantitative restrictions on allowances
Entitlement to allowances
For expenditure incurred on or after 1 April 2024, a lessor will be able to claim writing down allowances (WDA) at the applicable rate (most likely to be 6% as in most cases ships would be assessed as long life assets acquired with special rate expenditure, see CAA01/S104A (1)(c) and S104D (1)), on the first £100 million of expenditure, and at 6% on the second £100 million, see FA00/SCH22/PARA94 (3)(b), which also applies the CAA01/S104D (1) rate.
Between 1 January 2011 and 31 March 2024 writing down allowances were available on the first £40 million, and the second £40m at the applicable rates.
»Ê¹ÚÌåÓýapp applicable rate for a ship that is not a long life asset is as follows:
- No first year allowances;
- Writing-down allowance of 18% a year on the first £100 million (the normal rate specified at CAA01/S56 (1), see FAA00/SCH22/PARA94 (3A)(a));
- Writing-down allowance of 6% a year (the rate specified by CAA01/S104D) on the next £100 million;
- No allowances on any excess over £200 million.
»Ê¹ÚÌåÓýappse limits apply separately to each ship, FA00/SCH22/PARA95 (1).
Historic rates were as follows:
Expenditure incurred | Writing-down allowance on first £40m | Writing-down allowance on next £40m | Writing-down allowance on any excess over £80m |
Before 1 April 2012 | Nil | Nil | Nil |
1 April 2012 to 31 March 2019Ìý | 18% | 8% | 8% |
From 1 April 2019 to 31 March 2024 | 18% | 6% | 6% |
Ìý
Hybrid rate
WhereÌýa business's chargeable period spans the date the WDA rate is changed, a hybrid rate is used to calculate the rate of WDA for that transitional period - see CA23220 for more details on how to calculate the WDA rates for such periods.
Separate class pools
»Ê¹ÚÌåÓýapp expenditure that does qualify for allowances should be taken to separate 18% and 6% class pools.Ìý Expenditure on each qualifying ship should be allocated to the 18% class pool or the 6% class pool as appropriate.
References
FA00/SCH22/PARA94 (quantitative restrictions on allowances) | TTM17546 |
FA00/SCH22/PARA95 (1) (limits apply to cost of each ship) | TTM17551 |
Quantitative restrictions on allowances | TTM10400 |
Shared expenditure on ship | TTM10420 |
Cost of providing ship | TTM10430 |
Example of cost of providing ship and the quantitative restrictions | TTM10440 |