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HMRC internal manual

Tonnage Tax Manual

From
HM Revenue & Customs
Updated
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Tonnage tax groups: Demerger

Effect

Where that group had elected for tonnage tax, any singleton qualifying company, or new group that contains a qualifying company, resulting from a demerger of the original tonnage tax group, remains a tonnage tax company or group.  A deemed election continues in force and expires at the same time the original group election would have expired (paragraphs 127 and 128).

References

FA00/SCH22/PARA121 (meaning of ‘demerger’) TTM17681
   
FA00/SCH22/PARA127 (demerger of single company) TTM17711
FA00/SCH22/PARA128 (demerger of group) TTM17716
Meaning of demerger TTM12400