Corporation Tax Act 2010

[F1937FRing-fenced scheme losses and relevant scheme profitsU.K.

This section has no associated Explanatory Notes

(1)Subsection (2) applies if—

(a)a company makes one or more scheme losses in an accounting period in relation to a risk transfer scheme, and

(b)disregarding any profits or losses made otherwise than as a result of the scheme, the relevant group makes a pre-tax economic loss in the period as a result of fluctuations in the scheme rate, index or value.

(2)The relevant proportion of each scheme loss made by the company in the accounting period is a “ring-fenced scheme loss”.

(3) For this purpose “ the relevant proportion ” means—

where—

A is the total of the scheme losses made in the period in relation to the scheme by the members of the relevant group,

B is the total of the scheme profits made in the period in relation to the scheme by the members of the relevant group, and

C is the pre-tax economic loss referred to in subsection (1)(b).

(4)Subsection (5) applies if—

(a)a company makes one or more scheme profits in an accounting period in relation to a risk transfer scheme, and

(b)disregarding any profits or losses made otherwise than as a result of the scheme, the relevant group makes a pre-tax economic profit in the period as a result of fluctuations in the scheme rate, index or value.

(5)The relevant proportion of each scheme profit made by the company in the accounting period is a “relevant scheme profit”.

(6) For this purpose “ the relevant proportion ” means—

where—

A is the total of the scheme profits made in the period in relation to the scheme by the members of the relevant group,

B is the total of the scheme losses made in the period in relation to the scheme by the members of the relevant group, and

C is the pre-tax economic profit referred to in subsection (4)(b).]

Textual Amendments

F1Pt. 21A inserted (with effect in accordance with Sch. 16 para. 5 of the amending Act) by Finance Act 2010 (c. 13), Sch. 16 para. 3