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.
References
| FA00/SCH22/PARA57 (tax attributable to tonnage profits of CFC) | TTM17326 |
| FA00/SCH22/PARA4 (method of calculation of tonnage tax profits) | TTM17016 |
| Method of calculation | TTM01300 |