Corporation Tax Act 2010 section 326

The ring fence pool

Section 326 explains what makes up the ring fence pool used in calculating ring fence expenditure supplement for oil and gas companies, and sets out the rules for when amounts are added to or reduced from that pool.

  • The ring fence pool is built from three components: any carried forward qualifying Schedule 19B amount, the company's ring fence losses, and any post-commencement supplement.
  • Ring fence losses are added to the pool in the period they arise, and post-commencement supplement is added in the period for which it is claimed.
  • When a reduction is required in any accounting period, it is made after adding that period's ring fence losses but before calculating and adding any supplement claimed for that period.
  • The pool is also subject to an adjustment under section 328A which removes pre-2013 losses after the initial six accounting periods.

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