Taxes Consolidation Act 1997 Schedule 18B paragraph 24

Merger: between tonnage tax groups or companies

Paragraph 24 provides that where tonnage tax groups or tonnage tax companies merge, the resulting group is automatically treated as a tonnage tax group under a deemed group election, which runs until the longest surviving pre-merger election would have expired.

• Applies to mergers between two or more tonnage tax groups, between tonnage tax groups and tonnage tax companies, or between two or more tonnage tax companies.
• The group resulting from any such merger is treated as a tonnage tax group, as if it had made a group election.
• No formal new election is required — the deemed election arises automatically by virtue of the merger.
• The deemed election remains in force until the date on which the longest-running of the pre-merger tonnage tax elections would have expired.