TTM07200 | The ring fence: Reliefs and deductions

No deduction from tonnage tax profits

No relief, deduction or set-off of any description is allowed against a company's tonnage tax profits. No deductions may, for example, be made for

• losses arising in the shipping trade before entry to tonnage tax,

• losses arising from a non-tonnage tax trade,

• group relief surrendered by other group members, or

• interest paid.

See TTM07220 for the treatment of losses that accrued before entry into tonnage tax. Reliefs and deductions may be set off in the normal way against any profits of the tonnage tax company which fall outside the ring fence.

Treatment for corporate interest restriction

A tonnage tax company's tonnage tax profits for an accounting period (AP) are treated as nil for the purpose of calculating the company's adjusted Corporation Tax earnings for the AP under TIOPA10/PART10/CHAPTER6, the corporate interest retriction 'tax EBITDA', TIOPA10/S406 (2) and S455 (2). See example at CFM97910.

References