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HMRC internal manual

Oil Taxation Manual

Corporation tax ring fence: onshore allowance - transfer of allowance between sites


A company holding an amount of unactivated allowances in respect of a site (site A) may elect to transfer the whole or part of that amount to another site (site B), if the appropriate conditions are met:

  1. Every part of site B is, or is part of, an area in which the company is a licensee, and
  2. The election is made no earlier than the beginning of the third accounting period of the company after that in which the allowance was generated.

The election must specify:

  • the amount of onshore allowance to be transferred;
  • the site at which it was generated;
  • the site to which it is transferred; and
  • the accounting period in which it was generated.