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HMRC internal manual

Tonnage Tax Manual

Tax avoidance: Outline

It is a condition of remaining within Tonnage Tax that a company is not a party to any transaction or arrangement that is an abuse of the tonnage tax regime.

A transaction or arrangement is such an abuse if, in consequence, , the tonnage tax legislation falls to be applied in a way that results (or would but for this paragraph result) in:



  • a tax advantage being obtained for:



* a company other than a tonnage tax company, or
* a tonnage tax company in respect of its non-tonnage tax activities,


  • the amount of the tonnage tax profits of a tonnage tax company being artificially reduced.


FA00/SCH22/PARA41 (requirement not to enter into tax avoidance) TTM17246