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HMRC internal manual

Oil Taxation Manual

Capital allowances: ring fence expenditure supplement: unrelieved group ring fence profits


The amount on which RFES (pre- and post-commencement) can be claimed for an accounting period is reduced if there are taxable ring fence profits arising in a company within the same group for a corresponding accounting period. ‘Group’ has the same meaning as given by CTA2010\S152.

Taxable ring fence profits are defined in CTA2010\S314. They are an amount of ring fence profits chargeable to corporation tax in an accounting period, net of any group relief claimed under the group relief rules.

The group company’s accounting period is a corresponding accounting period if it coincides with, overlaps or falls wholly within the qualifying company’s accounting period. If it overlaps, the profits are apportioned in accordance with CTA2010\S1172.