SCHEDULES

SCHEDULE 22Tonnage tax

Part XIIGroups, mergers and related matters

Company not to be treated as member of more than one group

119

1

For the purposes of this Schedule a company may not, at the same time, be a member—

a

of a tonnage tax group and a qualifying non-tonnage tax group, or

b

of more than one tonnage tax group.

2

If the rules in paragraphs 116 to 118 would produce that result in relation to a company, the following rules apply.

3

As between a tonnage tax group and a qualifying non-tonnage tax group, the company shall be treated as a member of the tonnage tax group and not of the non-tonnage tax group.

4

As between two tonnage tax groups, the company shall be treated as a member of the group whose tonnage tax election was made first and not of the other tonnage tax group.

5

In the case of group elections made at the same time, the company may choose which election it joins in.

It is treated for the purposes of this Schedule as a member of the group in respect of which that election is made and not of any other tonnage tax group.