Tonnage Tax: UT upholds FTT decision in FC Shipping v HMRC

The Upper Tribunal has dismissed the taxpayers’ appeal in FC Shipping v HMRC [2026] UKUT 305 (TCC). The appeal concerned the application of the defeased leasing rules in the tonnage tax regime, the correct approach to measuring the reduction on non-compliance risk, and what constitutes relevant provisions for those purposes. The UT dismissed the taxpayers’ appeal on all grounds.

Ed Hellier acted for HMRC, led by Ben Elliott.