697Q Ten year disqualification from re-entry into tonnage tax

This section provides for disqualification from tonnage tax where a company leaves tonnage tax other than on the expiry of its election. A 10 year exclusion period will apply. Currently, this provision is of little practical application as there is no provision for entry into tonnage tax except by way of election in the initial period or election within 36 months of becoming a qualifying company – see paragraph 2 of Schedule 18B. Also there is currently no mechanism for re-entry to tonnage tax should a company exit after the expiry of the 10 year election period without making a renewals election. However, under paragraph 2(6) of Schedule 18B, the Minister for Finance can provide for additional periods in which a company may elect for tonnage tax. Any company excluded from tonnage tax under this section would not be able to re-enter the regime under any other election procedure which may be provided until the expiry of a 10 year period.

Relevant Date: Finance Act 2021