Paragraph 140
A company election made by a former tonnage tax company is ineffective if made before the end of the period of ten years beginning with the date on which the company ceased to be a tonnage tax company.
A group election that—
is made in respect of a group whose members include a former tonnage tax company, and
would result in that company becoming a tonnage tax company,
is ineffective if made before the end of the period of ten years beginning with the date on which that company ceased to be a tonnage tax company.
Sub-paragraphs (1) and (2) do not prevent a company becoming a tonnage tax company under and in accordance with the rules in Part XII of this Schedule (groups, mergers and related matters).
In this paragraph “former tonnage tax company” means a company that is not a tonnage tax company but has previously been a tonnage tax company.