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HMRC internal manual

Tonnage Tax Manual

Tonnage tax elections: When election takes effect

Foreign companies or groups new to the UK

Where a foreign company or group including companies operating qualifying ships comes to the UK for the first time, it will have 12 months to decide whether to elect into tonnage tax under FA00/SCH22/PARA10 (2) or (3).  If it decides to elect in, the election will have effect from the time that the group began ship operation in the UK.  If such an election is made, the group will be considered as a tonnage tax group from the moment it comes to the UK for the purposes of applying the rules on mergers set out in FA00/SCH22/PARA123 onwards.