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Legislation
Corporation Tax Act 2010

Crossheading Basic definitions

  • Section 937C Meaning of “risk transfer scheme”
  • Section 937D Meaning of “the scheme rate, index or value”
  • Section 937E Scheme losses and scheme profits
  • Section 937F Ring-fenced scheme losses and relevant scheme profits
  1. Basic definitions
  2. Ring-fenced scheme losses and relevant scheme profits

Section 937F | Ring-fenced scheme losses and relevant scheme profits

From legislation.gov.uk

(1)Subsection (2) applies if—

(a)a company makes one or more scheme losses in an accounting period in relation to a risk transfer scheme, and

(b)disregarding any profits or losses made otherwise than as a result of the scheme, the relevant group makes a pre-tax economic loss in the period as a result of fluctuations in the scheme rate, index or value.

(2)The relevant proportion of each scheme loss made by the company in the accounting period is a “ring-fenced scheme loss”.

(3)For this purpose “ the relevant proportion ” means—

Formula

A–B–CA

where—

A is the total of the scheme losses made in the period in relation to the scheme by the members of the relevant group,

B is the total of the scheme profits made in the period in relation to the scheme by the members of the relevant group, and

C is the pre-tax economic loss referred to in subsection (1)(b).

(4)Subsection (5) applies if—

(a)a company makes one or more scheme profits in an accounting period in relation to a risk transfer scheme, and

(b)disregarding any profits or losses made otherwise than as a result of the scheme, the relevant group makes a pre-tax economic profit in the period as a result of fluctuations in the scheme rate, index or value.

(5)The relevant proportion of each scheme profit made by the company in the accounting period is a “relevant scheme profit”.

(6)For this purpose “ the relevant proportion ” means—

Formula

A–B–CA

where—

A is the total of the scheme profits made in the period in relation to the scheme by the members of the relevant group,

B is the total of the scheme losses made in the period in relation to the scheme by the members of the relevant group, and

C is the pre-tax economic profit referred to in subsection (4)(b).

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