TTM10480 - Ship leasing: Quantitative restrictions on allowances
Restrictions begin to apply: Procedure
When the quantitative restrictions begin to apply, an appropriate amount must be taken out of the lessor바카라 사이트™s normal capital allowance pool, and a corresponding amount must be allocated to the 18% and 6% class pools.
Notional disposal
The first step is to bring an amount of notional disposal proceeds into account in the lessor바카라 사이트™s normal capital allowance pool at the beginning of the accounting period during which the change bringing the restrictions into force takes place.
The amount to be brought into account (referred to in the legislation as 바카라 사이트˜Amount A바카라 사이트™) is the lower of:
Ìý
- the total qualifying expenditure remaining in the pool at the beginning of that accounting period, and
- the 바카라 사이트˜tax written down value바카라 사이트™, see TTM10530, of the ship as at the beginning of that accounting period.
This step has the effect of removing the ship from the normal capital allowance pool.
Temporary pool
At the same time as the notional disposal proceeds are brought into account, an amount of qualifying expenditure equal to 바카라 사이트˜Amount A바카라 사이트™ is placed in a separate single asset pool (known as the 바카라 사이트˜temporary pool바카라 사이트™).
This temporary pool is then closed as at the date of the change bringing the restrictions into force.Ìý At that date the ship is treated as being disposed of for a notional amount (바카라 사이트˜Amount B바카라 사이트™) equal to the 바카라 사이트˜tax-written down value바카라 사이트™, see TTM10530, of the ship as at the date of the change. This will usually result in a balancing allowance or charge.
Opening and closing the temporary pool has the effect of giving the lessor capital allowances at the normal rate for the period from the start of the accounting period to the date of change.
Notional expenditure
The lessor is then treated as incurring new qualifying expenditure equal to Amount B on the ship that is subject to the finance lease as at the date of the change.
That expenditure is allocated to the lessor바카라 사이트™s 18% and 8% tonnage tax class pools in the same proportions as the lessor바카라 사이트™s original qualifying expenditure would have been allocated if the lease had been subject to the restrictions from the outset.
CAA01/S220 applies to time-apportion that expenditure for the period from when it is treated as incurred as would be the case for any other new expenditure on a finance leased asset, see CA28450.
This final step has the effect of giving restricted allowances for the remainder of the period from the date of the change.
바카라 사이트˜Tax written down value바카라 사이트™
See TTM10530Ìýfor details of how to work out the tax written down value of the ship as at the start of the accounting period, and at the date of the change.
Example
See TTM10490Ìýfor an example of how these provisions operate in practice
References
FA00/SCH22/PARA98 (change of circumstances bringing in case) | TTM17566 |
FA00/SCH22/PARA100 (tax written down value) | TTM17576 |
Restrictions begin to apply: Introduction | TTM10470 |
Restrictions begin to apply: Example | TTM10490 |