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HMRC internal manual

Tonnage Tax Manual

HM Revenue & Customs
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The ring fence: Reliefs and deductions

Tonnage tax profits of CFCs

The exclusion of reliefs or set-offs against the tax liability attributable to a company’s ‘tonnage tax profits (see TTM07200) also applies to the tax attributable to any ‘tonnage profits’ of a CFC which are included in the amounts apportioned to a company under step 3 in TIOPA10/S371BC (1).

(NB this restriction applies whether or not the company to which the profits are apportioned is itself subject to tonnage tax.)

The ‘tonnage profits’ of a CFC are the profits that are calculated by reference to tonnage (in accordance with paragraph 4). See TTM07100for details of how the profits of a CFC are calculated.

The tonnage profits of a CFC are to be treated as apportioned to a company in the same proportion that the CFC’s total profits are apportioned to it.


FA00/SCH22/PARA57 (tax attributable to tonnage profits of CFC) TTM17326
FA00/SCH22/PARA4 (method of calculation of tonnage tax profits) TTM17016
Method of calculation TTM01300