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HMRC internal manual

Tonnage Tax Manual

HM Revenue & Customs
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Tonnage tax groups: Merger

Between tonnage tax groups or companies

A merger between two tonnage tax companies or groups will always result in a new tonnage tax group. There will be a deemed election expiring:

  • If there is a dominant party, when that party’s tonnage tax election would have expired; or
  • If there is no dominant party, when whichever of the existing tonnage tax elections which had the longest period left to run would have expired.


FA00/SCH22/PARA122 (merger between TT groups/companies) TTM17686
FA00/SCH22/PARA126 (meaning of ‘dominant party’) TTM17706
Dominant party TTM12350