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HMRC internal manual

Oil Taxation Manual

Corporation Tax Ring Fence: The Supplementary Charge - Ring fence trading profit with negative financing costs

Where the deduction of negative financing costs simply reduces the adjusted ring fence profit to a smaller but still positive amount then all financing costs have been excluded in a computation of supplementary charge and no further adjustment is necessary.

If the amount of the negative financing costs exceeds the ring fence profit and has not yet been left out of account in computing Adjusted Ring Fence Profits, then the excess will need to be left out of account when computing Adjusted Ring Fence Profits of a subsequent period. As there is a ring fence profit there are no trading losses to be relieved.