Corporation Tax Act 2010 section 313

Unrelieved group ring fence profits for accounting periods

Section 313 defines "unrelieved group ring fence profits" for an accounting period, which is used to restrict the ring fence expenditure supplement where taxable ring fence profits exist elsewhere in the same corporate group.

• Where a qualifying company (company Q) and another group member (company X) belong to the same group, and company X has taxable ring fence profits in a corresponding period, company Q has unrelieved group ring fence profits for that period
• If company X's accounting period coincides with or falls wholly within company Q's accounting period, the full amount of company X's taxable ring fence profits counts as unrelieved group ring fence profits
• If company X's accounting period only partly overlaps with company Q's period, only a time-apportioned share of company X's taxable ring fence profits is included, based on the length of the overlap
• The unrelieved group ring fence profits reduce the pool of expenditure eligible for supplement under sections 318 or 328, reflecting that the losses could have been surrendered against those group profits instead