Relevant shipping income & core activities of a tonnage tax company - Section 115VI

Tonnage tax scope: defines relevant shipping income, limits incidental receipts, and prescribes market value transfers for computation.

Relevant shipping income comprises profits from core activities and prescribed incidental activities, with incidental receipts above a de minimis share of core turnover excluded and taxed under ordinary provisions. Core activities include operating qualifying ships and specified ship related or inland vessel activities such as pooling arrangements, contracts of affreightment, passenger on board/on shore receipts, charters and container leasing. Incidental activities include maritime consultancy, loading/unloading income, ship management fees and maritime education or recruitment fees. Income from non qualifying ships is computed under normal provisions; transfers between tonnage and other businesses are valued at market value unless the Assessing Officer adopts a reasonable basis, and related party adjustments may be made where arrangements produce abnormal profits.