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Legislation
Corporation Tax Act 2010

Crossheading Treatment of ring-fenced scheme losses

  • Section 937G Ring-fenced scheme loss: treatment in period in which made
  • Section 937H Ring-fenced scheme loss: treatment in subsequent periods
  1. Treatment of ring-fenced scheme losses
  2. Ring-fenced scheme loss: treatment in period in which made

Section 937G | Ring-fenced scheme loss: treatment in period in which made

From legislation.gov.uk

(1)This section applies for the purpose of determining the amount (if any) of a ring-fenced scheme loss that may be brought into account by a company in the accounting period in which it is made.

(2)If the amount of the company's profits pool for the scheme as at the beginning of the period is nil, the ring-fenced scheme loss may not be brought into account.

(3)If the amount of the company's profits pool for the scheme as at the beginning of the period is—

(a)greater than nil, and

(b)less than the total of the ring-fenced scheme losses made in the period in relation to the scheme by the company,

only the relevant proportion of the ring-fenced scheme loss may be brought into account.

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

Formula

AB

where—

A is the amount of the company's profits pool as at the beginning of the period, and

B is the total of the ring-fenced scheme losses made in the period in relation to the scheme by the company.

(5)If the amount of the company's profits pool for the scheme as at the beginning of the period is equal to or greater than the total of the ring-fenced scheme losses made in the period in relation to the scheme by the company, the ring-fenced scheme loss may be brought into account in full.

(6)A reference in this paragraph to bringing a ring-fenced scheme loss into account is to bringing it into account in determining a debit or credit for the purposes of Part 5 of CTA 2009 (loan relationships) or Part 7 of that Act (derivative contracts).

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