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HMRC internal manual

Tonnage Tax Manual

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

Controlled foreign companies legislation

A tonnage tax company is not subject to any liability under the CFC legislation in respect of the profits of a CFC, if in that period any distributions received by the company from that CFC would have been relevant shipping income, (see TTM07100).


FA00/SCH22/PARA54 (1) (controlled foreign companies) TTM17311