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HMRC internal manual

Tonnage Tax Manual

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HM Revenue & Customs
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Schedule 22 Finance Act 2000: Part VII the ring fence - Para 59 transactions not at arm's length - between Tonnage Tax trade and other activities of same company

FA00/SCH22/PARA59

(1) Part 4 of the Taxation (International and Other Provisions) Act 2010 (transactions not at arm’s length) applies to provision made or imposed as between a company’s tonnage tax trade and other activities carried on by it as if-

(a) that trade and those activities were carried on by two different persons,

(b) the provision were made or imposed between those persons by means of a transaction, and

(c) the two persons were both controlled by the same person at the time of the making or imposition of the provision.

(2) As applied by sub-paragraph (1), Part 4 of the Taxation (International and Other Provisions) Act 2010 has effect with the omission of sections 174 to 184, 187 to 189 and 191 to 196 (elimination of double counting etc).

(3) Expressions used Part 4 of the Taxation (International and Other Provisions) Act 2010 have the same meaning in this paragraph.

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

References

Transactions between divisions of a company TTM07320