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HMRC internal manual

Oil Taxation Manual

From
HM Revenue & Customs
Updated
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Corporation Tax Ring Fence: The Extension of the Ring Fence Extension Beyond Case 1

Ring fence income is not limited to income within Case I of Schedule D, it can extend to royalties and income within Case III and Case VI. Whether income falls within or without the ring fence boundary is a question of fact and in any particular case all the circumstances surrounding the particular source need to be considered.