Corporation Tax Act 2010 section 327

Reductions in respect of relief for carried-forward ring fence losses

Section 327 explains how the non-qualifying pool and ring fence pool are reduced when carried-forward ring fence losses are used against profits in a later period.

• When carried-forward ring fence losses are relieved against profits, the company's supplement pools must be reduced by the amount of relief obtained.
• The non-qualifying pool is reduced first; only if any balance remains after that pool reaches nil is the ring fence pool then reduced.
• Neither pool can be reduced below nil.
• The reduction amount includes both relief actually given and relief that was prevented from being given because the company elected to restrict it.