Taxes Consolidation Act 1997 Schedule 18B, paragraph 25

Merger: tonnage tax group/company and qualifying non-tonnage tax group/company

Paragraph 25 sets out the options available when a tonnage tax group or company merges with a qualifying non-tonnage tax group or company.

• This rule applies where a tonnage tax group or company merges with a group or company that qualifies for tonnage tax but has not elected into it.
• The resulting group may elect to be treated as if a group tonnage tax election had been made, with that deemed election remaining in force until the original election would have expired.
• Alternatively, the resulting group may elect for the existing tonnage tax election to cease from the date of the merger.
• The election must be made jointly by all qualifying companies in the resulting group, by written notice to Revenue within 12 months of the merger.

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