What are Qualifying Secondary Activites?

These are ship-related activities which are not the direct operation of the company’s own ships but have a substantial connection with the company’s or a fellow group member’s core qualifying activities. These include:

• Support services to fellow group member’s ships that would be qualifying core or secondary activities if carried out for own ships
• Carriage of passengers or cargo beyond the sea-leg of an inclusively priced journey where the transport is bought in from a third party
• Administration and insurance services
• Embarkation and disembarkation of passengers*
• Loading and unloading cargo*
• Excursions for passenger where cabin remains available to passenger
• Normal sales and services to, and entertainment of, passengers
• Similar services to third parties where use of surplus capacity
• Reciprocal arrangements with third parties
• not being part of the operation of a port

What is strategic and commercial management in the UK?

HM Revenue and Customs will adopt a common-sense interpretation, taking into account the various strands of activity carried out in the UK, including:

Strategic

Location of headquarters, including senior management staff
Decision-making of the company board of directors
Decision-making of operational board
UK stock exchange listing

Commercial

Route planning
Taking bookings for cargo or passengers
Managing the bunkers, provisioning and victualling requirements
Personnel management
Training organisation
Technical management of vessels
Extent to which foreign offices/branches work under the direction of UK-based personnel
Support facilities in the UK (e.g. training centre, terminal, etc.)

Other factors

Extent to which work is carried out in UK compared to elsewhere
Nature and extent of accommodation in UK
Number of employees in UK
Residence of key staff, including directors, in the UK
For an international group, a reasonable balance between UK activities and tonnage in the UK
Flagging, classing, insuring or financing of vessels in UK