»Ê¹ÚÌåÓýapp

Deductions from the tax liability

»Ê¹ÚÌåÓýapp tax liability attributable to a company’s tonnage tax profits is payable in full without any relief or set-off.

»Ê¹ÚÌåÓýapp only exceptions to this rule are that:
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• marginal smallÌýprofits relief remains available, and
• income tax borne by deduction may still be set-off.

»Ê¹ÚÌåÓýapp prohibition applies to exclude all other reliefs and set-offs, including (but not limited to):
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• 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 step 3 in TIOPA10/S371BC (1). See TTM07230.

See TTM07240 regarding ACT and shadow ACT.

References