Commentary

D7.1026 Tonnage tax—groups, mergers and demergers

Corporate tax
Corporate tax | Commentary

D7.1026 Tonnage tax—groups, mergers and demergers

Corporate tax | Commentary

D7.1026 Tonnage tax—groups, mergers and demergers

Groups

If a shipping company would otherwise be a member of two groups, one of which elected for tonnage tax and one of which did not, then it is a member of the tonnage tax group. If it would be a member of two groups, both of which elected for tonnage tax, then it is a member of the group that elected first1.

A group is defined as:

  1.  

    (a)     all the companies controlled by an individual; or

  2.  

    (b)     a company and all the companies that it controls, where it is not controlled by another person2.

An individual will control a company if he controls it alone, or together with his associate(s), but he will not be treated as controlling a company if he has no significant

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