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Official guidance
Corporate Finance Manual

CFM63300 · Foreign exchange: matching: anti-avoidance: FA2010: risk transfer schemes

  • CFM63310 · FA2010: risk transfer schemes: introduction
  • CFM63320 · FA2010: risk transfer schemes: example
  • CFM63330 · FA2010: risk transfer schemes: summary of the legislation
  • CFM63340 · FA2010: risk transfer schemes: meaning of ‘risk transfer scheme’: condition 1
  • CFM63350 · FA2010: risk transfer schemes: meaning of ‘risk transfer scheme’: conditions 2 and 3
  • CFM63360 · FA2010: risk transfer schemes: scheme losses and scheme profits
  • CFM63370 · FA2010: risk transfer schemes: calculating the ring-fenced losses
  • CFM63380 · FA2010: risk transfer schemes: calculating the relevant scheme profits
  • CFM63390 · FA2010: risk transfer schemes: the losses pool
  • CFM63400 · FA2010: risk transfer schemes: the profits pool
  • CFM63410 · FA2010: risk transfer schemes: utilising ring-fenced losses: same period
  • CFM63420 · FA2010: risk transfer schemes: utilising ring-fenced losses: subsequent periods
  • CFM63430 · FA2010: risk transfer schemes: ‘economic’ profits and losses
  • CFM63440 · FA2010: risk transfer schemes: the group
  1. Foreign exchange: matching: anti-avoidance: FA2010: risk transfer schemes: Contents
  2. FA2010: risk transfer schemes: the losses pool

CFM63390 | FA2010: risk transfer schemes: the losses pool

From HM Revenue & Customs · Corporate Finance Manual

In order to calculate the amounts of any ring-fenced scheme losses (CFM63370) that can be offset against relevant scheme profits (CFM63380) in any accounting period, it is necessary to keep track of the pool of losses that have been ring-fenced. This is termed the ‘losses pool’ and the rules for calculating the amount at the beginning of any accounting period are at CTA10/S937I(2).

The losses pool is:

The amount of the losses pool at the beginning of the previous accounting period (or nil if the scheme did not exist until the current period), PLUS

Any ring-fenced scheme losses in the previous period that were not utilised in that period, LESS

Any ring-fenced losses brought forward into the previous period that were utilised in the previous period.

Although this formula may appear complicated, in most circumstances the result will be relatively simple, as the following example demonstrates:

Example

Company X has made the following ring-fenced scheme losses and relevant scheme profits from a risk transfer scheme:

y/e 31 December 2010 - £y/e 31 December 2011 - £y/e 31 December 2012 - £
Ring-fenced losses300,000-?
Relevant scheme profits-100,000-

The losses pool at the start of the year ended 31 December 2012 would be as follows:

£300,000 + £0 - £100,000 = £200,000

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