TTM07210 - The Ring Fence: Reliefs and deductions
The tax liability attributable to a company’s tonnage tax profits is payable in full without any relief or set-off.
The only exceptions to this rule are that:
- marginal small companies relief remains available
- income tax borne by deduction may still be set-off
The prohibition applies to exclude all other reliefs and set-offs, including (but not limited to);
- double taxation relief, and
- unrelieved surplus ACT
This exclusion also applies to the tax attributable to any tonnage tax profits of a CFC that are included in amounts apportioned to a company under ICTA88/S737(3). See TTM07230
See TTM07240 regarding ACT and shadow ACT.
FA00/SCH22/PARA57 (exclusion of set-off against tax liability)
Reliefs and deductions against profits