Section 115VZB - Avoidance of tax

Abuse of tonnage tax scheme barred where arrangements produce a tax advantage for non-tonnage parties or activities.

Section 115VZB excludes application of the tonnage tax scheme where a tonnage tax company engages in transactions or arrangements that amount to an abuse by producing a tax advantage for others or for the company in respect of non-tonnage activities. The Explanation clarifies that such tax advantage includes adjustments to allowances, costs or interest allocation that reduce taxable income or increase losses for non-tonnage activities, and transactions producing more than ordinary profits from tonnage activities.