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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 XIV leaving Tonnage Tax - Para 139 exit charge - balancing charges

FA00/SCH22/PARA139

(1) This paragraph applies if in a relevant accounting period during which the company was a tonnage tax company it was liable to a balancing charge in relation to which paragraph 78 (phasing-out of balancing charges) applied to reduce the amount of the charge.

(2) For this purpose a “relevant accounting period” means an accounting period ending not more than six years before the day on which the company ceased to be a tonnage tax company.

(3) The company is treated as having received an additional amount of profits chargeable to corporation tax equal to the aggregate of the amounts by which those balancing charges were reduced.

(4) Those additional profits are treated-

(a) as arising immediately before the company ceased to be a tonnage tax company, and

(b) as not being relevant shipping profits of the company.

(5) No relief, deduction or set-off of any description is allowed against those profits or against corporation tax on them.

References

Exit charge: balancing charge TTM14220