OT21067 | Corporation Tax Ring Fence: Losses and Group Relief: Change in Company Ownership: Introduction

This guidance sets out how HMRC will apply the anti-avoidance rules in CTA10/Part14 to companies carrying on a ring fence trade. Ring fence trades are defined in statute as comprising the oil related activities (CTA10/S274) of a company. Because the scope of a ring fence trade is set in statute, there has been some uncertainty about whether there could be a major change in the nature or conduct of a company’s ring fence trade. The main guidance on Part 14 (see CTM06300) does not deal with ring fence trades specifically, so this guidance supplements it, to cover the specific situation where a company has a ring fence trade.