Corporation Tax Act 2010 section 356GD

Unactivated amounts attributable to a reference period

Section 356GD sets out how to calculate the total unactivated onshore allowance attributable to a particular reference period and site, for the purposes of the allowance activation rules.

  • The total unactivated allowance for a reference period and site is calculated using the formula P + Q − R.
  • P is the allowance generated by the company at the site during the reference period, including any amounts treated as generated there through transfers between sites or equity disposals.
  • Q is the unactivated allowance brought forward — either from a preceding accounting period or from an immediately preceding reference period, depending on the circumstances.
  • R is any reduction required where the company has disposed of all or part of its equity share in a licensed area that is or includes the site.

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