HMRC internal manual

Tonnage Tax Manual

TTM12350 - Tonnage tax groups: Merger

Meaning of ‘dominant party’

The ‘dominant party’ to a merger is the party with more than twice the turnover, generated by relevant activities, than the other party. If neither party qualifies as the dominant party, there is no dominant party (FA00/SCH22/PARA126(2)).

For the meaning of ‘relevant activities’, which can have different meanings in different circumstances, see TTM12360.


FA00/SCH22/PARA122 (merger between TT groups/companies) TTM17686
FA00/SCH22/PARA123 (merger between T and QNT) TTM17686
FA00/SCH22/PARA125 (merger between NQ and QNT) TTM17701
FA00/SCH22/PARA126 (meaning of ‘dominant party’) TTM17706
Merger between tonnage tax groups or companies TTM12310
Merger between T and QNT TTM12320
Merger between NQ and QNT TTM12340