(1) No relief, deduction or set-off of any description is allowed against the amount of a company's tonnage tax profits.
(a) When a company enters tonnage tax, any losses that have accrued to it before entry and are attributable -
(i) to activities that under tonnage tax become part of the company's tonnage tax trade, or
(ii) to a source of income that under tonnage tax becomes relevant shipping income,
shall not be available for loss relief in any accounting period beginning on or after the company's entry into tonnage tax.
(b) Any apportionment necessary to determine the losses so attributable shall be made on a just and reasonable basis.
(c) In paragraph (a) 'loss relief' includes any means by which a loss might be used to reduce the amount in respect of which that company, or any other company, is chargeable to tax.
(a) Any relief or set-off against a company's tax liability for an accounting period shall not apply in relation to so much of that tax liability as is attribut
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