Taxation (International and Other Provisions) Act 2010 section 455

Shipping companies subject to tonnage tax

Section 455 provides that shipping companies within the tonnage tax regime must exclude their tonnage tax profits when calculating their tax-EBITDA for corporate interest restriction purposes.

• This section applies to any accounting period of a company that is subject to the tonnage tax regime for shipping.
• When calculating a tonnage tax company's adjusted corporation tax earnings (tax-EBITDA), its tonnage tax profits are treated as nil.
• This means tonnage tax profits do not increase the company's interest deduction capacity under the corporate interest restriction rules.
• "Tonnage tax company" and "tonnage tax profits" take their meanings from Schedule 22 to the Finance Act 2000.