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 partyâ€� 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 partyâ€� (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