Corporation Tax Act 2010 section 303A

Introduction to sections 303B to 303D: post-1 April 2017 non-decommissioning losses of ring fence trades

Section 303A defines what constitutes a "non-decommissioning loss" in a ring fence trade for oil activities, distinguishing it from losses arising from decommissioning expenditure covered by a decommissioning relief agreement.

• A loss from a ring fence trade is a "non-decommissioning loss" to the extent it is not caused by expenditure linked to a decommissioning relief agreement
• The portion of a loss attributable to decommissioning expenditure is the lower of the total decommissioning expenditure included in the loss calculation, or the loss itself
• Expenditure qualifies as "relevant expenditure" if it is decommissioning expenditure as defined by HMRC's decommissioning relief agreement framework under Finance Act 2013
• This section sets the foundation for sections 303B to 303D, which deal with how post-1 April 2017 non-decommissioning losses of ring fence trades are carried forward and used