Taxes Consolidation Act 1997 Schedule 18B paragraph 27

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

Paragraph 27 allows a group formed by the merger of a non-qualifying group or company with a qualifying non-tonnage tax group or company to elect for tonnage tax within 12 months of the merger.

  • Applies where a non-qualifying group or company merges with a qualifying non-tonnage tax group or company
  • The resulting group may make a tonnage tax election with effect from the date of the merger
  • The election must be made jointly by all qualifying companies in the resulting group
  • Written notice must be given to Revenue within 12 months of the merger

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