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HMRC internal manual

Tonnage Tax Manual

HM Revenue & Customs
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The ring fence: contents


This section explains why relevant income of a tonnage tax company is ring fenced and how legislation works to isolate these tonnage tax profits. This section covers the introduction of new accounting periods, the treatment of income from controlled foreign companies, and calculation of allowable finance costs. It also explains the rules that prevent deductions being made from tonnage tax profits.