What was the purpose of section 329Q of the Corporation Tax Act 2010?

Section 329Q addressed the onshore ring fence pool, a mechanism used in calculating supplementary charge relief for oil and gas companies operating in the UK onshore area. It formed part of Chapter 5A (sections 329A–329T), which provided specific rules for relief against the supplementary charge on ring fence profits from onshore activities.

When was section 329Q of the Corporation Tax Act 2010 repealed?

Section 329Q was repealed by Finance Act 2015, Schedule 11, paragraph 13, which removed the entire Chapter 5A. The repeal was given retrospective effect, applying to all accounting periods ending on or after 5 December 2013, meaning companies had to treat the provisions as unavailable from that date.

How does the retrospective repeal date of 5 December 2013 affect oil and gas companies?

Companies with accounting periods ending on or after 5 December 2013 cannot rely on section 329Q or any Chapter 5A provision. A company whose accounting period ended before that date could still apply the provisions. This distinction is critical when reviewing historical tax computations around that period.

What reliefs are available to UK onshore oil and gas companies after the repeal of Chapter 5A?

Following the repeal of Chapter 5A, companies engaged in UK onshore oil and gas extraction must look to other provisions of the tax code for any available reliefs against the supplementary charge. The specific supplementary charge relief rules that were contained in Chapter 5A, including the onshore ring fence pool, are no longer available.

Corporation Tax Act 2010 section 329Q

The onshore ring fence pool

Section 329Q dealt with the onshore ring fence pool, a mechanism previously used in the calculation of supplementary charge relief for oil and gas companies operating in the UK onshore area. This section has been repealed.

Section 329Q was part of Chapter 5A (sections 329A–329T) of the Corporation Tax Act 2010, which dealt with supplementary charge relief provisions for oil and gas activities.
The entire Chapter 5A was repealed by Finance Act 2015 (Schedule 11, paragraph 13).
The repeal took effect in relation to accounting periods ending on or after 5 December 2013, meaning the provisions are treated as no longer applying from that date.
Companies that may have relied on these provisions for earlier periods should note the retrospective nature of the repeal date when reviewing historical tax computations.

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