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HMRC internal manual

Tonnage Tax Manual

From
HM Revenue & Customs
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Tonnage tax elections: When election takes effect

Group companies with different accounting periods and ‘initial period’ election

Where companies in a group have different accounting dates the rules on when a tonnage tax election takes effect are applied separately to each company by reference to the date of the group election and the accounting period of that company.

However, a group election must be applied consistently.  The group cannot seek to backdate the date of entry for some companies at the same time that it is seeking to defer entry for others.  Whatever rule applies must be applied consistently to the particular circumstances of each company in the group.

See the example in TTM02303.

References

FA00/SCH22/PARA12(5) (different accounting periods) TTM17056