The ring fence: Reliefs and deductions
ACT and shadow ACT
As described in TTM07210, unrelieved surplus ACT may not be set of against tax chargeable which is attributable to a company’s tonnage tax profits (or which is attributable to the tonnage tax profits of a CFC which have been apportioned to a company
under step 3 in TIOPA10/S371BC (1).
Conversely, per FA00/SCH22/PARA57 (5), a company’s tonnage tax profits are to be left out of account in determining the company’s profits charged to corporation tax for the purposes of the shadow ACT regulations (FA98/S32 and SI99/358).
But this does not affect the computation (under those Regulations) of shadow ACT on distributions made by a tonnage tax company, whether paid out of tonnage tax profits or other profits.
|FA00/SCH22/PARA57 (5) (ACT and shadow ACT)||TTM17326|