TTM06450 - Relevant shipping profits: Distributions from qualifying overseas shipping companies
Subject to tax
In FA00/SCH22/PARA49 (2)(f) there is a condition that the profits from which the dividends are paid must be subject to tax, see TTM06410.
This test may still be satisfied even if there is no actual liability to tax on those profits (for example because of the operation of loss relief), so long as the profits in question are 바카라 사이트˜subject to a tax on profits바카라 사이트™.
The rules of computation for tax purposes of those profits are also immaterial - for example, dividends paid by a company within a comparable tonnage tax regime in another country would satisfy the 바카라 사이트˜subject to a tax바카라 사이트™ test.
References
| FA00/SCH22/PARA49 (2)(f) (subject to tax test) | TTM17286 |