Corporation Tax Act 2010 section 356F

Transfer of allowances between sites

Section 356F allows a company with onshore allowances on one site to elect to transfer all or part of those unused allowances to another site where it holds a licence, subject to timing and other conditions.

• A company may transfer all or part of its unactivated onshore allowance from one site to another site where it is a licensee, by making an election.
• The transfer election cannot be made until the start of the third accounting period after the one in which the allowance was originally generated.
• The election must specify the amount being transferred, the originating site, the receiving site, and the accounting period in which the allowance was generated.
• Once transferred, the allowance is treated as having been generated at the new site at the beginning of the accounting period in which the election is made.