TTM12100 - Tonnage Tax Groups: Control
Different methods of attribution could result in a tonnage tax company becoming a member of more than one tonnage tax group.
A company cannot be a member at the same time of a tonnage tax group and a qualifying non-tonnage tax group. A ‘qualifying non-tonnage tax group’ is one which could have elected into Tonnage Tax, but chose not to. If a company is a member of both such groups, then it is treated as a member of the tonnage tax group only, and not the other group (paragraph 119(3).
A company also cannot be a member at the same time of more than one tonnage tax group. If it is, then it is treated as a member of the tonnage tax group that made a tonnage tax election first. It is the date of the first election that is the decider, not the date the group entered Tonnage Tax. Where, exceptionally, the group elections were made on the same day, the company itself may choose which tonnage tax group it joins (paragraph 119(4) & (5)).
FA00/SCH22/PARA119 (not a member of more than one group)
Meaning of ‘control’