Income Tax Act 2007 section 80

Ring fence income

Section 80 restricts the use of trade losses against ring fence income from oil extraction activities or oil rights.

• Income from oil extraction activities or oil rights is classified as "ring fence income"
• A person who makes a trade loss cannot offset it against their ring fence income unless the loss itself arises from oil extraction activities or oil rights
• This prevents non-oil trade losses from reducing taxable profits earned within the oil ring fence
• The definitions of "oil extraction activities" and "oil rights" are set out in sections 225A and 225B of ITTOIA 2005