Abuse of tonnage tax scheme: transactions creating tax advantage can disqualify regime benefits for the company. Section 115VZB excludes the tonnage tax regime where a tonnage tax company enters into transactions or arrangements that result, or would have resulted but for the section, in a tax advantage for others or for the company's non-tonnage activities, including through determination, allocation or apportionment of expenses, interest or costs in the company's books, or where the arrangement produces more than ordinary profits from tonnage tax activities.
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Provisions expressly mentioned in the judgment/order text.
Abuse of tonnage tax scheme: transactions creating tax advantage can disqualify regime benefits for the company.
Section 115VZB excludes the tonnage tax regime where a tonnage tax company enters into transactions or arrangements that result, or would have resulted but for the section, in a tax advantage for others or for the company's non-tonnage activities, including through determination, allocation or apportionment of expenses, interest or costs in the company's books, or where the arrangement produces more than ordinary profits from tonnage tax activities.
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