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HMRC internal manual

Tonnage Tax Manual

Relevant shipping profits: Distributions from qualifying overseas shipping companies

Disposal of overseas business

HMRC accepts that profits arising on the disposal of all or part of an overseas shipping business may be paid out as dividends under the rules described in TTM06410, provided that the overseas company has qualified to pay such dividends for the five years prior to the disposal.

(HMRC does not accept that profits on the disposal of shares in an overseas shipping company are relevant shipping profits under these rules.  Such a profit will fall outside the tonnage tax ring fence.)