Section 937F — Corporation Tax Act 2010: Ring-fenced scheme losses and relevant scheme profits

Ring-fenced scheme losses and relevant scheme profits 937F 1 Subsection (2) applies if—

a a company makes one or more scheme losses in an accounting period in relation to a risk transfer scheme, and b disregarding any profits or losses made otherwise than as a result of the scheme, the relevant group makes a pre-tax economic loss in the period as a result of fluctuations in the scheme rate, index or value.

2 The relevant proportion of each scheme loss made by the company in the accounting period is a “ring-fenced scheme loss”.

3 For this purpose “ the relevant proportion ” means— A – B – C A where— A is the total of the scheme losses made in the period in relation to the scheme by the members of the relevant group, B is the total of the scheme profits made in the period in relation to the scheme by the members of the relevant group, and C is the pre-tax economic loss referred to in subsection (1)(b).

4 Subsection (5) applies if—

a a company makes one or more scheme profits in an accounting period in relation to a risk transfer scheme, and b disregarding any profits or losses made otherwise than as a result of the scheme, the relevant group makes a pre-tax economic profit in the period as a result of fluctuations in the scheme rate, index or value.

5 The relevant proportion of each scheme profit made by the company in the accounting period is a “relevant scheme profit”.

6 For this purpose “ the relevant proportion ” means— A – B – C A where— A is the total of the scheme profits made in the period in relation to the scheme by the members of the relevant group, B is the total of the scheme losses made in the period in relation to the scheme by the members of the relevant group, and C is the pre-tax economic profit referred to in subsection (4)(b).