Commentary

D7.1025 Offshore activities

Corporate tax
Corporate tax | Commentary

D7.1025 Offshore activities

Corporate tax | Commentary

Tonnage tax—Special provisions

D7.1025 Offshore activities

Where a qualifying ship (D7.1004) operated by a tonnage tax company is used for offshore activities, special rules apply in relation to:

  1.  

    (a)     profits from the service element of these activities;

  2.  

    (b)     capital allowances; and

  3.  

    (c)     capital gains.

These special rules do not apply if, during any accounting period, the use for offshore activities is for 30 days or less. The 30-day limit applies to the total number of days for all of the company's qualifying ships, not separately for each ship1. A period of inactivity is not treated as a period of offshore activity unless the inactivity specifically relates to a pending offshore activity and it is

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