Part 4

Loss relief
Chapter 2

Trade losses

Carry-forward trade loss relief

Ring fence trades
87
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).