Energy (Oil and Gas) Profits Levy Act 2022 section 11

Limitation on amount of levy group relief to be given

Section 11 sets out the limits on how much Energy Profits Levy group relief a claimant company can receive, by applying the existing corporation tax group relief caps (from CTA 2010) with appropriate modifications for the levy.

• The amount of levy group relief a company can claim is subject to the same general limitations that apply to ordinary corporation tax group relief under sections 138 to 142 of CTA 2010, adapted for the levy.
• Where the standard group relief rules refer to "total profits," this is replaced with "qualifying levy profits" for Energy Profits Levy purposes, ensuring the cap is calculated by reference to the correct profit measure.
• The claimant company's available qualifying levy profits are its qualifying levy profits after deducting any relief already given under the main levy relief provision (paragraph 1 of Schedule 1 to the Act).
• The overlapping period rules — which determine the common accounting period between surrendering and claimant companies — are adapted to reference the levy group relief requirements rather than the standard corporation tax group relief conditions.