Tonnage tax exclusion: losses and ordinary deductions for qualifying ship operations are barred while prior shipping losses receive restricted set off treatment. Clause 230 provides that for a company chargeable under the tonnage tax scheme ordinary losses, allowances and deductions are to be treated as if given full effect in the relevant year but specified loss carry forwards and set offs relating to qualifying ship operations are disallowed; ordinary deductions for shipping profits are barred and depreciation values are computed as if depreciation had been claimed. Pre option losses attributable to the tonnage tax business are treated as having been set off against relevant shipping income while under the scheme and thereafter cannot be set off against non shipping income, with apportionment on a reasonable basis.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Tonnage tax exclusion: losses and ordinary deductions for qualifying ship operations are barred while prior shipping losses receive restricted set off treatment.
Clause 230 provides that for a company chargeable under the tonnage tax scheme ordinary losses, allowances and deductions are to be treated as if given full effect in the relevant year but specified loss carry forwards and set offs relating to qualifying ship operations are disallowed; ordinary deductions for shipping profits are barred and depreciation values are computed as if depreciation had been claimed. Pre option losses attributable to the tonnage tax business are treated as having been set off against relevant shipping income while under the scheme and thereafter cannot be set off against non shipping income, with apportionment on a reasonable basis.
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