A qualifying ship that is engaged in offshore activities remains a qualifying ship. The offshore profits remain relevant shipping profits. The special rules therefore contain a number of provisions to ensure that offshore profits are brought into charge as intended.
•Offshore profits are charged to tax as if they were not relevant shipping profits by FA00/SCH22/PARA107 (1).
•The ring fence provisions apply as if the offshore activities were not tonnage tax activities, FA00/SCH22/PARA108 (1).
•The tonnage tax provisions apply to offshore profits in the same way that they would apply to profits other than relevant shipping profits, FA00/SCH22/PARA108 (2).