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HMRC internal manual

Tonnage Tax Manual

Tonnage tax groups: Merger

Between tonnage tax and qualifying non-tonnage tax groups or companies

Where there is a merger between a tonnage tax company or group (T) and a qualifying non-tonnage tax company or group (QNT), then:

  • if T is the dominant party, the new group will be a tonnage tax group with a deemed election expiring when T’s election would have expired; or
  • if QNT is the dominant party, then the new group will not be within tonnage tax, and T’s election will expire as at the date of merger; or
  • if there is no dominant party, the new group may elect that T be treated as the dominant party, with the consequences as set out above. Such an election must be made jointly by all qualifying companies in the new group by notice in writing to HMRC within 12 months of the date of merger.


FA00/SCH22/PARA123 (merger between T and QNT) TTM17691
FA00/SCH22/PARA126 (meaning of ‘dominant party) TTM17706
Dominant party TTM12350
Effect of exiting tonnage tax regime TTM14100
Election after merger TTM02170
Definitions of T and QNT TTM12300