OT21077 | Corporation Tax Ring Fence: The treatment of repayments of PRT

CTA10\S300

Subject to the provision for the carry back of PRT losses (see OT21076), where PRT that has been allowed as a deduction in the CT Ring Fence computation is subsequently repaid, then the deduction is reduced or extinguished.

Any additional assessment to CT to bring the PRT repayment into charge must be made within 4 years of the end of the calendar year in which the PRT repayment was made.