(1) In this section -
'control' shall be construed in accordance with section 11;
'losses' includes amounts in respect of which relief may be given in accordance with section 83(3) and Part 12;
'transaction' includes any agreement, arrangement or understanding of any kind (whether or not it is, or is intended to be, legally enforceable).
(2) Where -
(a) provision is made or imposed as between a tonnage tax company and another company by means of a transaction,
(b) the results of the transaction are taken into account in computing the tonnage tax company's relevant shipping income,
(c) at the time of the transaction -
(i) one of the companies is directly or indirectly under the control of the other, or
(ii) both of the companies are, directly or indirectly, under the control of the same person or persons,
and
(d) the relevant shipping income of the tonnage tax company is greater than it would be if the parties to the transaction had been independent parties dealing at arm's length,
then
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