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HMRC internal manual

Tonnage Tax Manual

The ring fence: Reliefs and deductions

No deduction from tonnage tax profits

No relief, deduction or set-off of any description is allowed against a company’s tonnage tax profits.

For example, no deduction may be made for:

  • losses arising in the shipping trade before entry to Tonnage Tax
  • losses arising from a non-tonnage tax trade
  • group relief surrendered by other group members
  • interest paid

See TTM07220 for the treatment of losses that accrued before entry into Tonnage Tax.

(NB Reliefs and deductions may be set off in the normal way against any profits of the tonnage tax company, which fall outside the ring fence.)


FA00/SCH22/PARA55 (general exclusion of reliefs) TTM17316
Deduction for tax liability TTM07210