If a company wishes to remain within the tonnage tax regime, it must not enter into any transaction or arrangement that is an abuse of that regime (ie one which results in a tax advantage being obtained, or an artificial reduction in tonnage tax profits being obtained). 'Tax advantage' has the same meaning as in CTA 2010, s 732 and broadly includes access to a relief or increased relief, a repayment or increased repayment, the avoidance or reduction in assessment to tax etc.
The
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