TTM17351 - Schedule 22 Finance Act 2000: Part VII the ring fence - Para 62 treatment of finance costs - group company

FA00/SCH22/PARA62

(1) This paragraph applies to a tonnage tax company which is a member of a tonnage tax group where the activities carried on by the members of the group include activities other than tonnage tax activities.

(2) An adjustment shall be made if it appears, in relation to an accounting period of the company, that the group바카라 사이트檚 deductible finance costs outside the ring fence exceed a fair proportion of the total finance costs of the group.

(3) A group바카라 사이트檚 바카라 사이트渄eductible finance costs outside the ring fence바카라 사이트� means so much of the group바카라 사이트檚 finance costs as may be brought into account in calculating for the purposes of corporation tax-

(a) in the case of a group member that is a tonnage tax company, the company바카라 사이트檚 profits other than relevant shipping profits, and

(b) in the case of a group member that is not a tonnage tax company, the company바카라 사이트檚 profits.

(4) A group바카라 사이트檚 바카라 사이트渢otal finance costs바카라 사이트� means so much of the group바카라 사이트檚 finance costs as could, if there were no tonnage tax election, be brought into account in calculating for the purposes of corporation tax the profits of any member of the group.

(5) What proportion of the group바카라 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 relevant proportion of 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.

For this purpose 바카라 사이트渢he relevant proportion바카라 사이트� is the proportion that the company바카라 사이트檚 tonnage tax profits bear to the tonnage tax profits of all the members of the group.

References

Outline of finance costs adjustment TTM07400
听 听
Finance costs of group companies TTM07430

听