OT21066 - Corporation Tax Ring Fence: Losses and Group Relief: Extended Carry Back for General Decommissioning and Terminal Losses - Example

For APE 31 Mar 2009, Company A made ring fence losses attributable to decommissioning expenditure of £1,000m and non-ring fence profits of £5³¾. The results of earlier APs and the loss relief available are as follows:

APE Ring Fence Non-ring fence Loss relief Allowed under
31 March 2009 (£1,000³¾) £5³¾ £5³¾ CTA10\S37
31 March 2008 £10³¾ £15³¾ £25³¾ CTA10\S40
31 March 2007 £20³¾ £10³¾ £30³¾ CTA10\S40
31 March 2006 £25³¾ £15³¾ £40³¾ CTA10\S40
31 March 2005 £50³¾ £30³¾ £50³¾ CTA10\S42
31 March 2004 £100³¾ £50³¾ £100³¾ CTA10\S42
31 March 2003 £365³¾ £60³¾ £349³¾ CTA10\S42

Total relief given is £599m, leaving ring fence losses available to carry forward of £401m.