TTM07210 - The ring fence: Reliefs and deductions

Deductions from the tax liability

The tax liability attributable to a company’s tonnage tax profits is payable in full without any relief or set-off.

The only exceptions to this rule are that:
 

• marginal small profits relief remains available, and
• income tax borne by deduction may still be set-off.

The prohibition applies to exclude all other reliefs and set-offs, including (but not limited to):
 

• double taxation relief, and
• unrelieved surplus ACT.

This exclusion also applies to the tax attributable to any tonnage tax profits of a CFC that are included in amounts apportioned to a company under step 3 in TIOPA10/S371BC (1). See TTM07230.

See TTM07240 regarding ACT and shadow ACT.

References

FA00/SCH22/PARA57 (exclusion of set-off against tax liability)	TTM17326
Reliefs and deductions against profits	TTM07200