SCHEDULES

SCHEDULE 22 Tonnage tax

Part XIV Withdrawal of relief etc. on company leaving tonnage tax

Exit charge: chargeable gains

138

1

Paragraph 65(1)(a) (chargeable gain: disposal of tonnage tax assets) has effect in relation to gains (but not losses) on all relevant disposals as if the company had never been a tonnage tax company.

2

For this purpose a “relevant disposal” means a disposal—

a

on or after the day on which the company ceases to be a tonnage tax company, or

b

at any time during the period of six years immediately preceding that day when the company was a tonnage tax company.

3

Where sub-paragraph (1) operates to increase the amount of the chargeable gain on a disposal made at a time within the period mentioned in sub-paragraph (2)(b), the gain is treated to the extent of the increase—

a

as arising immediately before the company ceased to be a tonnage tax company, and

b

as not being relevant shipping profits of the company.

4

No relief, deduction or set-off of any description is allowed against the amount of that increase or the corporation tax on that amount.