Corporation Tax Act 2010 section 356NJ

Modification of provisions restricting the use of losses

Section 356NJ ensures that losses set against a company's contractor's ring fence profits are excluded from the general corporation tax loss restriction rules, thereby protecting the ring fence regime for oil contractor activities.

• Losses carried forward under section 45A (post-1 April 2017 trade losses) and set against contractor's ring fence profits are not treated as relevant deductions for the purposes of the restriction on deductions from total profits.
• Group relief for carried-forward losses claimed under Part 5A and set against contractor's ring fence profits is similarly excluded from the total profits deduction restriction.
• Pre-1 April 2017 trade losses arising from oil contractor activities and carried forward under section 45(4)(b) are ignored when calculating the restriction on deductions from trading profits.
• The overall effect is that the corporate loss restriction rules do not limit a company's ability to relieve losses within the oil contractor ring fence.