TTM12300 - Tonnage tax groups: Merger

Meaning

Definition

‘Merger’ is defined by FA00/SCH22/PARA121 (1) as a transaction by which one or more companies become members of a group. Therefore the ‘merger’ rules apply to acquisitions as well as mergers.

The merger may be between any combination of:

T tonnage tax company or group;

QNT qualifying non-tonnage tax company or group; that is, a company or group that would have qualified for Tonnage Tax but is not covered by an election; and

NQ non-qualifying non-tonnage tax company or group; that is, a company or group that would not have qualified for making a tonnage tax election.

Types of merger

Between T and T TTM12310

Between T and QNT TTM12320

Between T and NQ TTM12330

Between NQ and QNT TTM12340

References

FA00/SCH22/PARA121 TTM17681