OT26185 | Capital allowances: ring fence expenditure supplement: post-commencement pools - reductions in respect of unrelieved group ring fence profits

CTA2010\S328

If, after making reductions in respect of utilised ring fence losses (see OT26180), there are unrelieved group ring fence profits for a post-commencement period then reductions in the pools are made as follows:

If the company does not have a non-qualifying pool, the remaining amount in the ring fence pool is reduced by the amount of the unrelieved group ring fence profits of the period (CTA2010\S328(2)). Where these unrelieved profits exceed the amount in the ring fence pool then the amount in the pool is reduced to nil, but the pool continues in existence (CTA2010\S325(2)).

If the company has a non-qualifying pool, the amount in that pool is reduced by the amount of the unrelieved group ring fence profits of the period (CTA2010\S328(3)). If the unrelieved profits exceed the amount in the non-qualifying pool, the amount in the pool is reduced to nil, and the pool ceases to exist (CTA2010\S325(4)).