Corporation Tax Act 2010 section 356DA

Carrying forward of activated allowance

Section 356DA provides that where a company's cumulative activated onshore allowance exceeds its adjusted ring fence profits in an accounting period, the unused portion is carried forward to the next accounting period.

  • Applies where a company's cumulative total of activated allowance is greater than its adjusted ring fence profits for an accounting period
  • The excess amount (the difference between activated allowance and adjusted ring fence profits) is carried forward to the next accounting period
  • Ensures that onshore allowances are not lost simply because there are insufficient profits in a given period to use them
  • The carried-forward amount becomes available to reduce the supplementary charge on ring fence profits in future periods

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