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