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HMRC internal manual

Oil Taxation Manual

Capital allowances: extended ring fence expenditure supplement for onshore activities - unrelieved group ring fence profits

CTA2010\S329H, CTA2010\S329L

Unrelieved group ring fence profits

For the purposes of ERFES unrelieved group ring fence profits has the same meaning as in sections 313 and 314 of Chapter 5, OT26125.

The amount on which ERFES, both pre- and post-commencement, can be claimed for an accounting period is reduced in accordance with the rules as set out in CTA2010\S329L 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 in CTA2010\S152.