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HMRC internal manual

Tonnage Tax Manual

From
HM Revenue & Customs
Updated
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Tonnage tax groups: Merger

Meaning

Definition

‘Merger’ is defined by FA00/SCH22/PARA121 (1) as a transaction by which one or more companies become members of a group.  Therefore the ‘merger’ rules apply to acquisitions as well as mergers.

The merger may be between any combination of:
 

T tonnage tax company or group;
   
QNT qualifying non-tonnage tax company or group; that is, a company or group that would have qualified for Tonnage Tax but is not covered by an election; and
NQ non-qualifying non-tonnage tax company or group; that is, a company or group that would not have qualified for making a tonnage tax election.

Types of merger

Between T and T TTM12310
   
Between T and QNT TTM12320
Between T and NQ TTM12330
Between NQ and QNT TTM12340

References

FA00/SCH22/PARA121 TTM17681