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HMRC internal manual

Oil Taxation Manual

Corporation Tax Ring Fence: Losses and Group Relief: Extended Carry Back for General Decommissioning and Terminal Losses - Example

For APE 31 Mar 2009, Company A made ring fence losses attributable to decommissioning expenditure of £1,000m and non-ring fence profits of £5m. The results of earlier APs and the loss relief available are as follows:

APE Ring Fence Non-ring fence Loss relief Allowed under
31 March 2009 (£1,000m) £5m £5m CTA10\S37
31 March 2008 £10m £15m £25m CTA10\S40
31 March 2007 £20m £10m £30m CTA10\S40
31 March 2006 £25m £15m £40m CTA10\S40
31 March 2005 £50m £30m £50m CTA10\S42
31 March 2004 £100m £50m £100m CTA10\S42
31 March 2003 £365m £60m £349m CTA10\S42

Total relief given is £599m, leaving ring fence losses available to carry forward of £401m.