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HMRC internal manual

Tonnage Tax Manual

From
HM Revenue & Customs
Updated
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Schedule 22 Finance Act 2000: Part VII the ring fence - Para 58 transactions not at arm's length - between Tonnage Tax company and another person

FA00/SCH22/PARA58

(1) In relation to provision made or imposed as between a tonnage tax company and another person by a transaction or series of transactions that-

(a) falls in relation to the tonnage tax company to be regarded as made or imposed in the course of, or with respect to, its tonnage tax trade, and

(b) does not fall in relation to the other person to be regarded as made or imposed in the course of, or with respect to, a tonnage tax trade carried on by that person,

Part 4 of the Taxation (International and Other Provisions) Act 2010 (transactions not at arm’s length) has effect with the omission of Sections 174 to 184, 187 to 189 and 191 to 196 (elimination of double counting etc).

(2) Expressions used in Part 4 of the Taxation (International and Other Provisions) Act have the same meaning in this paragraph.

(3) Nothing in this paragraph affects the computation of a company’s tonnage tax profits.

References

Transfer pricing TTM07300