Taxation (International and Other Provisions) Act 2010 Explanatory Notes

Section 205: Provision made or imposed between ring-fence trade and other activities

410.If provision is made or imposed as between the ring-fence trade of an oil company and other activities of that company this section has the effect that this Part applies as if that trade and those other activities were carried on by two separate persons controlled by the same person. It is based on paragraph 11(1), (3) and (4) of Schedule 28AA to ICTA.

411.In subsection (1)(a) the words “oil-related” have been added to “ring-fence trade” in paragraph 11(1) and (3) of Schedule 28AA to make clear the area of taxation referred to. “Oil-related ring-fence trade” is defined in section 206.

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