TTM07210 - The Ring Fence: Reliefs and deductions

Deductions from the tax liability

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