TTM17346 - Schedule 22 Finance Act 2000: Part VII the ring fence - Para 61 treatment of finance costs - single company
FA00/SCH22/PARA61
(1) This paragraph applies to a tonnage tax company which is a single company carrying on tonnage tax activities and other activities.
(2) An adjustment shall be made if it appears, in relation to an accounting period of the company, that the company바카라 사이트檚 deductible finance costs outside the ring fence exceed a fair proportion of the company바카라 사이트檚 total finance costs.
(3) The company바카라 사이트檚 바카라 사이트渄eductible finance costs outside the ring fence바카라 사이트� means the total of the amounts that may be brought into account in respect of finance costs in calculating for the purposes of corporation tax the company바카라 사이트檚 profits other than relevant shipping profits.
(4) A company바카라 사이트檚 바카라 사이트渢otal finance costs바카라 사이트� means so much of the company바카라 사이트檚 finance costs as could, if there were no tonnage tax election, be brought into account in calculating the company바카라 사이트檚 profits for the purposes of corporation tax.
(5) What proportion of the company바카라 사이트檚 total finance costs should be deductible outside the ring fence shall be determined on a just and reasonable basis by reference to the extent to which the funding in relation to which the costs are incurred is applied in such a way that any profits arising, directly or indirectly, would be relevant shipping profits.
(6) Where an adjustment falls to be made under this paragraph, an amount equal to the excess referred to in sub-paragraph (2) shall be brought into account as if it were a non-trading credit falling for the purposes of Part 5 of the Corporation Tax Act 2009 (loan relationships) to be brought into account in respect of a loan relationship of the company in respect of non-tonnage tax activities.
References
| Outline of finance costs adjustment | TTM07400 |
| 听 | 听 |
| Finance costs of singleton company | TTM07420 |
听