Section 205 | Provision made or imposed between ring-fence trade and other activities

(1)Subsections (2) to (4) apply if—

(a)a person carries on an oil-related ring-fence trade (see section 206), and

(b)any provision is made or imposed by the person as between—

(i)the oil-related ring-fence trade, and

(ii)any other activities carried on by the person.

(2)Chapters 1 and 3 to 6 (read in accordance with Chapters 2 and 8) apply in relation to the provision as if—

(a)the oil-related ring-fence trade, and the person's other activities, were carried on by two different persons,

(b)the provision were made or imposed as between those two persons by means of a transaction,

(c)those two persons were both controlled by the same person at the time when the provision was made or imposed, and

(d)a potential advantage in relation to United Kingdom taxation were conferred by the provision on each of those two persons.

(3)Subsection (2) has effect subject to subsection (4).

(4)Chapters 1 and 3 to 6 apply in relation to the provision only if the effect of their applying is—

(a)that a larger amount is taken for tax purposes to be the amount of the profits of the oil-related ring-fence trade for any chargeable period, or

(b)that a smaller amount (including nil) is taken for tax purposes to be the amount for any chargeable period of any losses of the oil-related ring-fence trade.

(5)In subsection (4)(a), the reference to a larger amount includes, if there would not otherwise have been profits, an amount of more than nil.