Beta This part of GOV.UK is being rebuilt – find out what this means

HMRC internal manual

Tonnage Tax Manual

From
HM Revenue & Customs
Updated
, see all updates

Schedule 22 Finance Act 2000: Part XII groups - Para 123 merger - Tonnage Tax group or company and qualifying non-Tonnage Tax group or company

FA00/SCH22/PARA123

(1) This paragraph applies where there is a merger between a tonnage tax group or company (“T”) and a qualifying non-tonnage tax group or company (“QNT”).

(2) If T is the dominant party, the group resulting from the merger is a tonnage tax group as if a group election had been made.

That deemed election continues in force, subject to the provisions of this Schedule, until T’s election would have expired.

(3) If QNT is the dominant party, T’s tonnage tax election ceases to be in force as from the date of the merger.

(4) If there is no dominant party-

(a) the group resulting from the merger may elect that T shall be treated as the dominant party (with the result that sub-paragraph (2) applies), and

(b) if it does not do so, T’s tonnage tax election ceases to be in force as from the date of the merger.

(5) Any election under sub-paragraph (4)(a) must be made-

(a) jointly by all the qualifying companies in the group resulting from the merger,

(b) by notice to the Inland Revenue,

(c) within twelve months of the merger.

References

Merger between T and QNT TTM12320