On 21 July 2009, HMRC published a briefing page, Revenue & Customs Brief 42/09, announcing its change of view on the treatment under tonnage tax of specialist ships that provide transportation in connection with other services of a kind necessarily provided at sea (see ¶790-580 and FA 2000, Sch. 22, para. 19(1)). In summary, the announcement indicates that the Revenue accept that it is not necessary to apportion the profits from operating a specialist ship between the transport element (tonnage tax) and the service element (outside tonnage tax), as summarised below.

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