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HMRC internal manual

Tonnage Tax Manual

From
HM Revenue & Customs
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Relevant shipping profits: Distributions from qualifying overseas shipping companies

Outline

Distributions received from an overseas company (that is, a company that is not resident in the UK) may be ‘relevant shipping income’ (see TTM06020) in the hands of a tonnage tax company if certain conditions are met, see TTM06410.

Such distributions will not give rise to any charge to tax outside the tonnage tax ring- fence.

The timing of such distributions is discussed at TTM06430.

Dividends received indirectly

Distributions may be received through a chain of overseas companies, but each of those companies must itself satisfy the conditions described in TTM06420.

Supporting information

Where dividends from overseas shipping companies are returned as relevant shipping income, the company is expected to supply appropriate details with the supporting computations. These details should include:
 

  • details of the ship (name, IMO number, type of charter, etc), and
  • a copy of the accounts for each foreign company from which the dividend is received covering both

    • the period in which the dividend is paid, and
    • the period out of the profits of which it is paid.

References

FA00/SCH22/PARA49 (distributions of overseas shipping companies) TTM17286