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HMRC internal manual

Oil Taxation Manual

Capital allowances: ring fence expenditure supplement: ring fence losses - post-commencement pools of losses

CTA2010\S325, CTA2010\S326

For the purpose of determining the amount of any post-commencement RFES a qualifying company has two pools of losses: a qualifying poolof E&A losses and a non-qualifying pool of losses (CTA2010\S325).

The ring fence pool (CTA2010\S326) 

This is a mixed pool of the company’s qualifying E&A losses and post commencement supplement. It contains:

  • the carried forward qualifying Schedule 19B amount,
  • the company’s ring fence losses, and
  • post-commencement RFES.

The ‘carried forward Schedule 19B amount’ is the amount in the company’s qualifying pool for EES purposes immediately before 1 January 2006. This includes losses arising from qualifying E&A expenditure and any EES claimed and allowed (see OT26098).

Even if the amount in this pool reduces to nil, the pool continues in existence.

The ‘non-qualifying pool’ 

This pool consists of the carried forward non-qualifying Schedule 19B amount. This is the amount in the company’s non-qualifying pool for EES purposes immediately before 1 January 2006. It includes any ring fence losses arising in periods prior to 1 January 2004 carried forward to later periods under CTA2010\S45 plus losses arising from 1 January 2004 to 31 December 2005 from expenditure not qualifying as E&A expenditure (see OT26097).

When the amount in the non-qualifying pool reduces to nil, the pool ceases to exist.