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HMRC internal manual

Oil Taxation Manual

Capital allowances: extended ring fence expenditure supplement for onshore activities - additional supplement in respect of a post-commencement period

CTA2010\S329N, CTA2010\S329O

A qualifying company (OT26203) which incurs an onshore ring fence loss in a post-commencement period can claim ERFES under the rules for post-commencement supplement. An onshore ring fence loss is defined in CTA2010\S329P (OT26255).

Post-commencement ERFES is calculated at the relevant percentage of the reference amount for each post-commencement period.

The reference amount (CTA2010\S329T) is the amount in the ERFES onshore ring fence pool (OT26260) after making adjustments for utilised ring fence losses and unrelieved group ring fence profits. If the post-commencement accounting period is less than 12 months long, the ERFES rate is reduced proportionately (CTA2010\S329O).

Making claims

Claims for post-commencement ERFES are made separately for each accounting period. Effect is given to a claim by treating the amount of post-commencement ERFES as if it were a loss incurred in carrying on the ring fence trade in that period, and which is set off against ring fence profits of succeeding periods under CTA2010\S45.

The time limits for making a claim are the same limits as apply for making group relief claims as set out in FA98\Sch18\para74, normally 12 months after the filing date for the claimant company’s return.

A company does not have to claim, or claim the full amount of ERFES, for a period.