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HMRC internal manual

Tonnage Tax Manual

Tonnage tax groups: Merger

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

A merger between a tonnage tax company or group (T) and a non-qualifying company or group (NQ) will always result in a new tonnage tax group, with T’s election continuing to apply to the new group.

References

FA00/SCH22/PARA124 (merger between T and NQ) TTM17696
   
FA00/SCH22/PARA126 (meaning of ‘dominant party’) TTM17706
Definitions of T and NQ TTM12300