TTM07230 | The ring fence: Reliefs and deductions

Tonnage tax profits of CFCs

The exclusion of reliefs or set-offs against the tax liability attributable to a company’s ‘tonnage tax profits', see TTM07200, also applies to the tax attributable to any ‘tonnage profits’ of a CFC which are included in the amounts apportioned to a company under step 3 in TIOPA10/S371BC (1).

This restriction applies whether or not the company to which the profits are apportioned is itself subject to tonnage tax.

The ‘tonnage profits’ of a CFC are the profits that are calculated by reference to tonnage. See TTM07100 for details of how the profits of a CFC are calculated.

The tonnage profits of a CFC are to be treated as apportioned to a company in the same proportion that the CFC’s total profits are apportioned to it.

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