TTM14110 - Exiting tonnage tax: Effects of exiting tonnage tax regime
Ten year disqualification
No re-entry into tonnage tax for ten years
For all cases, except on expiry of an election, there is a ten year disqualification from re-entry into tonnage tax under FA00/SCH22/PARA137 (3).Ìý »Ê¹ÚÌåÓýapp ten years will run from the first day after leaving tonnage tax.Ìý If a further window of opportunity were offered for entry into the regime, a company could still not re-enter if any part of its first accounting period following re-entry into tonnage tax would fall within the ten year disqualification period.
Exception to ten year disqualification rule
»Ê¹ÚÌåÓýapp only exception to this rule is where, under the merger rules, either:
- an ex-tonnage tax group or company were taken over by a tonnage tax group or company which was the ‘dominant party� or, there being no dominant party, which could elect to be so (FA00/SCH22/PARA123), or
- an ex-tonnage tax group or company were taken over by a non-qualifying group or company which was the ‘dominant party� (PARA125).
In those limited circumstances an ex-tonnage tax company can re-enter tonnage tax before the expiry of its ten year disqualification period.
Ìý
»Ê¹ÚÌåÓýapp ten year disqualificationv period does not apply to a company which remains in a group which continues to be a tonnage tax group because at least one other company in the group is a tonnage tax company, see TTM14030.
References
FA00/SCH22/PARA140 (ten year disqualification from re-entry) | TTM17776 |
FA00/SCH22/PARA137 (company ceases to be tonnage tax company) | TTM17761 |
FA00/SCH22/PARA123 (merger between T and QNT) | TTM17691 |
FA00/SCH22/PARA125 (merger between NQ and QNT) | TTM17701 |
Merger between T and QNT | TTM12320 |
Merger between NQ and QNT | TTM12340 |