Corporation Tax Act 2010 section 356NF

Group relief and group relief for carried-forward losses

Section 356NF restricts the use of group relief and group relief for carried-forward losses against a company's contractor's ring fence profits, ensuring that only losses arising from oil contractor activities can be set against those profits.

• Group relief from another group company's losses cannot be set against a claimant company's contractor's ring fence profits unless those losses arose from oil contractor activities
• The same restriction applies to group relief for carried-forward losses — only losses from oil contractor activities in the surrendering company can offset contractor's ring fence profits
• When calculating how much a company can surrender as group relief, its relevant contractor's ring fence profits are excluded from its gross profits, with an adjustment where the company has made qualifying charitable donations
• Where a company has made qualifying charitable donations allowable for the period, the relevant contractor's ring fence profits are reduced by the amount of those donations before being excluded from the gross profits calculation