Corporation Tax Act 2010 section 328

Reductions in respect of unrelieved group ring fence profits

Section 328 explains how the expenditure pools eligible for ring fence expenditure supplement must be reduced where a company has unrelieved group ring fence profits in a post-commencement period.

• Where unrelieved group ring fence profits exist for a post-commencement period, the company's expenditure pools must be reduced after any prior reductions under section 327 have been made.
• If the company has no non-qualifying pool, the total unrelieved group ring fence profits are set against the remaining ring fence pool balance, reducing it but not below nil.
• If the company does have a non-qualifying pool, the unrelieved group ring fence profits are first set against that pool (not below nil), and any excess is then set against the remaining ring fence pool (also not below nil).
• The "remaining amount in the ring fence pool" means whatever balance is left in the ring fence pool after any reductions required by section 327 have already been applied.