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HMRC internal manual

Tonnage Tax Manual

HM Revenue & Customs
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Schedule 22 Finance Act 2000: Part VII the ring fence - Para 56 exclusion of loss relief


(1) When a company enters tonnage tax, any losses that have accrued to it before entry and are attributable-

(a) to activities that under tonnage tax become part of the company’s tonnage tax trade, or

(b) to a source of income that under tonnage tax becomes relevant shipping income,

are not available for loss relief in any accounting period beginning on or after the company’s entry into tonnage tax.

(2) Any apportionment necessary to determine the losses so attributable shall be made on a just and reasonable basis.

(3) In sub-paragraph (1) “loss relief” includes any means by which a loss might be used to reduce the amount in respect of which that company, or any other company, is chargeable to tax.


Pre-Tonnage Tax loss TTM07220
Offshore losses TTM11230