Corporation Tax Act 2010 section 330

Supplementary charge in respect of ring fence trades

Section 330 imposes an additional 10% tax charge on the adjusted profits of companies carrying on oil and gas ring fence trades, calculated after stripping out financing costs.

  • A company carrying on a ring fence trade is charged an additional 10% on its adjusted ring fence profits, treated as corporation tax.
  • Adjusted ring fence profits are the company's ring fence profits recalculated on the assumption that all financing costs are excluded from the computation.
  • Financing costs must also be excluded when calculating any ring fence loss relief surrendered to the company by another group member.
  • The supplementary charge may be reduced by investment allowance, onshore allowance or cluster area allowance, and further adjusted where decommissioning expenditure has been taken into account.

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