SCHEDULE 22 Tonnage tax
Part VII The ring fence: general provisions
Profits of controlled foreign companies
54
(1)
A tonnage tax company is not subject to any liability F1at step 5 in section 371BC(1) of the Taxation (International and Other Provisions) Act 2010 (“TIOPA 2010”) in any accounting period in respect of profits of a F2CFC if in that period distributions of the F2CFC made to the tonnage tax company would be relevant shipping income of the latter (see paragraph 49)F3; and, accordingly, the tonnage tax company is not to be a chargeable company for the purposes of Part 9A of TIOPA 2010 in relation to the CFC's accounting period in question.
F4(2)
In relation to a CFC which—
(a)
is a member of a tonnage tax group, and
(b)
is a tonnage tax company by virtue of the group's tonnage tax election, or would be if it were within the charge to corporation tax,
the corporation tax assumptions within the meaning of Part 9A of TIOPA 2010 are to be taken to include the following assumption.
(3)
The CFC is to be assumed to be a single company that is a tonnage tax company.
(4)
Nothing in section 371SL(1) of TIOPA 2010 affects sub-paragraphs (2) and (3) above.
(5)
In this paragraph “CFC” has the same meaning as in Part 9A of TIOPA 2010.