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.U.K.
(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.