Corporation Tax Ring Fence: Tariff Receipts and Tax-Exempt Tariffing Receipts
Tariff receipts (see OT15000) and tax-exempt tariffing receipts (see OT15800) which would not otherwise be within the ring fence are brought in by CTA10\S291. Tariff receipts and tax-exempt tariffing receipts are considered in detail in the PRT section of this manual.
A few additional notes may be useful.
- For income to be within CTA10\S291 it must also be within the charge to PRT. Where this is not so, then tariff receipts and tax-exempt tariffing receipts can still be within the RF if they fall within the various definitions.
- Where a company is connected with a participator and receives tariff receipts or tax-exempt tariffing receipts, which for PRT purposes are attributable to the participator, the tariffing activity is within the ring fence. (CTA10\S291(6)).
- Where tariff receipts or tax-exempt tariffing receipts are received by a participator in a foreign (e.g. Norwegian) field for UK use of a field asset, these are within PRT and are brought within the ring fence by OTA83\Sch4\Para16.
- In certain circumstances where the chargeable field for tariff income for PRT purposes would otherwise change, FA99\S98 deems the recipient to remain or to become a participator in the PRT field (OT15150). The recipient is then also deemed to be a participator in the PRT field for the purposes of CTA10\S291 and other relevant sections.