188体育

Tonnage tax profits of CFCs

The exclusion of reliefs or set-offs against the tax liability attributable to a company鈥檚 鈥榯onnage tax profits', see TTM07200, also applies to the tax attributable to any 鈥榯onnage profits鈥� of a CFC which are included in the amounts apportioned to a company under step 3 in TIOPA10/S371BC (1).
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This restriction applies whether or not the company to which the profits are apportioned is itself subject to tonnage tax.

The 鈥榯onnage profits鈥� of a CFC are the profits that are calculated by reference to tonnage. See TTM07100听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鈥檚 total profits are apportioned to it.

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