Commentary

D4.813 Companies subject to tonnage tax

Corporate tax
Corporate tax | Commentary

D4.813 Companies subject to tonnage tax

Corporate tax | Commentary

D4.813 Companies subject to tonnage tax

The provisions in this article apply only to companies where an election has not been made for exemption for the profits of a foreign permanent establishment (D4.801). For details of the double tax relief provisions that generally apply equally to companies and individuals see Division E6.4.

Special provisions1 apply to a UK company that is subject to the UK tonnage tax regime which receives a dividend from an overseas company, the activities of which would wholly fall within the UK tonnage tax regime, were it UK resident. Such dividends are effectively subsumed within the tonnage

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