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HMRC internal manual

Tonnage Tax Manual

Tonnage tax elections: When to elect?

Window of opportunity when opportunity to elect under the merger provisions

Under FA00/SCH22/PARA123(5) and PARA125(3) of the group merger provisions, a 12-month window of opportunity may be given in certain circumstances for the new group to elect into tonnage tax, even though a constituent part of the new group may have chosen not to elect in when it first had the opportunity.

The window of opportunity in these circumstances is 12 months from the day of the merger. See TTM12340.


FA00/SCH22/PARA123(5) (merger between T and QNT) TTM17691
FA00/SCH22/PARA125(3) (merger between NQ and QNT) TTM17701