TTM07000 – The Ring Fence

Table of contents

Outline and basic concept

TTM07001Outline
TTM07010Accounting periods
TTM07020Tonnage tax trade

Controlled foreign companies

TTM07100Outline of Tonnage Tax and CFCs
TTM07110CFC is a qualifying overseas shipping company
TTM07120CFC is not a qualifying overseas shipping company, but operates qualifying ships

Reliefs and deductions

TTM07200No deduction from tonnage tax profits
TTM07210Ring-fencing of tax liability
TTM07220Pre-tonnage tax losses
TTM07230Tonnage tax profits of CFC
TTM07240ACT and shadow ACT

Transfer pricing

TTM07300Outline of transfer pricing
TTM07310Between companies
TTM07320Within a company
TTM07330Duty to notify connected parties

Finance costs

TTM07400Outline of finance costs adjustment
TTM07410Meaning of ‘finance costs’
TTM07420Singleton company
TTM07430Group companies

Interaction of finance costs and transfer pricing

TTM07500Interaction of finance costs and transfer pricing
TTM07510Intragroup interest-free loans: Examples


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