Transfer pricing applicability to tonnage tax scheme narrowed; tonnage-covered operations exempted from transfer pricing obligations.
Transfer pricing provisions were held inapplicable to operations covered by the Tonnage Tax Scheme, and transfer pricing adjustments based on differential interest for a bareboat charter cum demise lease were rejected in light of prior consistent rulings. The Tribunal treated the relevant interest income and expenditure as business income, examined whether a negative lien equated to a fee-bearing corporate guarantee, and reviewed allocation principles for common interest and hire-charge adjustments between tonnage and non-tonnage activities.