OT26160 - Capital allowances: ring fence expenditure supplement: ring fence losses and qualifying and non-qualifying E&A losses
CTA2010\S323, CTA2010\S324
»Ê¹ÚÌåÓýapp starting point for a claim to post-commencement RFES for an accounting period is a loss arising in the ring fence trade in the period that could be carried forward under CTA2010\S45, S45B and S303B and set against future trading profits.
»Ê¹ÚÌåÓýapp company is then assumed to have made every possible claim under CTA2010\S37 to set losses of the period against ring-fence profits of earlier post-commencement periods. This applies whether or not a claim under CTA2010\S37 is actually made.
»Ê¹ÚÌåÓýapp balance of the ring fence trading loss after those assumed CTA2010\S37 claims is the ‘ring fence lossâ€� of the accounting period. This amount is added to the ‘ring fence poolâ€� for the period of loss.
Special rules apply to determine the ‘ring fence lossâ€� where the loss in the ring fence trade arises in the part of the straddling period that begins on 1 January 2006 (the ‘deemed accounting periodâ€�). »Ê¹ÚÌåÓýappse are explained in OT26165.