125(1)This paragraph applies where there is a merger between a non-qualifying group or company (“NQ”) and a qualifying non-tonnage tax group or company.U.K.
(2)In that case, if NQ is the dominant party the group resulting from the merger may make a tonnage tax election having effect as from the date of the merger.
(3)Any such election must be made—
(a)jointly by all the qualifying companies in the group resulting from the merger,
(b)by notice to the Inland Revenue,
(c)within twelve months of the merger.