TTM07240 - The Ring Fence: Reliefs and deductions

ACT and shadow ACT

As described inTTM07210, unrelieved surplus ACT may not be set of against taxchargeable which is attributable to a company’s tonnage tax profits (or which is attributable to the tonnage tax profits of a CFC which have been apportioned to a company under ICTA88/S737(3)).

Conversely, per paragraph 57(5), a company's tonnage tax profits are to be left out of account in determining the company's profits charged to corporation tax for the purposes of the shadow ACT regulations (FA98/S32 and SI99/358).

But this does not affect the computation (under those regulations) of shadow ACT on distributions made by a tonnage tax company, whether paid out of tonnage tax profits or other profits.

References

FA00/SCH22/PARA57(5) (ACT and shadow ACT)

TTM17326