TTM12300 - Tonnage Tax Groups: Merger
Meaning
Definition
‘Merger’ is defined by paragraph 121(1) as a transaction by which one or more companies become members of a group.
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
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Between T and T |
|
|
Between T and QNT |
|
|
Between T and NQ |
|
|
Between NQ and QNT |
References
|
FA00/SCH22/PARA121 |
