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.