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HMRC internal manual

Oil Taxation Manual

Corporation Tax Ring Fence: The Supplementary Charge - Interaction with Ring Fence losses

In 2007 HMRC & UKOITC discussed the treatment of the supplementary charge and “losses”. HMRC’s position is set out in the following sections. This position was circulated to the members of UKOITC in HMRC’s letter of 7 June 2007.