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Taxes Consolidation Act, 1997 (Number 39 of 1997)


697M Exclusion of reliefs, deductions and set-offs.

(1) No relief, deduction or set-off of any description is allowed against the amount of a company’s tonnage tax profits.

(2) (a) When a company enters tonnage tax, any losses that have accrued to it before entry and are attributable—

(i) to activities that under tonnage tax become part of the company’s tonnage tax trade, or

(ii) to a source of income that under tonnage tax becomes relevant shipping income,

shall not be available for loss relief in any accounting period beginning on or after the company’s entry into tonnage tax.

(b) Any apportionment necessary to determine the losses so attributable shall be made on a just and reasonable basis.

(c) In paragraph (a)loss relief” includes any means by which a loss might be used to reduce the amount in respect of which that company, or any other company, is chargeable to tax.

(3) (a) Any relief or set-off against a company’s tax liability for an accounting period shall not apply in relation to so much of that tax liability as is attributable to the company’s tonnage tax profits.

(b) Relief to which this subsection applies includes, but is not limited to, any relief or set-off under section 826, 828 or Part 2 of Schedule 24.

(c) This subsection shall not apply to any set-off under section 24(2) or 25(3).




Inserted by FA02 s53(1). FA03 s62 amends FA03 s53 to provide that Part 24A will take effect from the date of passing of FA03, 28 March 2003.