SCHEDULES

SCHEDULE 22 Tonnage tax

Part XII Groups, mergers and related matters

Merger: tonnage tax group or company and qualifying non-tonnage tax group or company

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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.