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    Continuity of Tonnage Tax Benefits in Shipping Sector Demergers : Clause 233(5)-(6) of Income Tax Bi...
    Continuity of Tonnage Tax Benefits in Shipping Amalgamations : Clause 233(1)-(4) of the Income Tax B...
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    Act RulesBills
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    Continuity of tonnage tax benefits preserves scheme application for qualifying companies after demerger, subject to statutory conditions.
    Where a demerged company transfers its business to a resulting company before expiry of its tonnage tax option, the tonnage tax scheme shall, subject to other provisions, apply to the resulting company for the unexpired period if it is a qualifying company; similarly, the demerged company retains its option for the unexpired period if it continues to be a qualifying company, with both continuities conditional on statutory eligibility, procedural compliance, and anti-avoidance requirements.
    Act RulesBills
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    Continuity of tonnage tax: amalgamated qualifying shipping companies retain the scheme subject to qualifying status and option deadlines.
    Clause 233(1)-(4) secures continuity of the tonnage tax regime on amalgamation by applying the scheme to the amalgamated company if it remains a qualifying company, requiring non-tonnage amalgamated companies to elect the scheme within a prescribed short period, granting the amalgamated entity the longest unexpired option period when multiple merging companies are under the scheme, and excluding entities that failed to elect during the original implementation window from accessing the regime post-amalgamation.

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