Part 4Loss relief

Chapter 2Trade losses

Carry-forward trade loss relief

87Ring fence trades

(1)

This section applies if—

(a)

a person makes a loss in a tax year carrying on oil-related activities (within the meaning of section 16 of ITTOIA 2005),

(b)

those activities are treated under that section as a separate trade for the tax year or a subsequent tax year,

(c)

the person makes profits in a subsequent tax year from other activities, and

(d)

the other activities and the oil-related activities would, but for that section, together form a single trade.

(2)

For the purposes of carry-forward trade loss relief for the loss, the person may treat profits from the other activities in a subsequent tax year as if they were profits of the separate trade (despite section 16 of ITTOIA 2005).