Section 937G — Corporation Tax Act 2010: Ring-fenced scheme loss: treatment in period in which made

Ring-fenced scheme loss: treatment in period in which made 937G 1 This section applies for the purpose of determining the amount (if any) of a ring-fenced scheme loss that may be brought into account by a company in the accounting period in which it is made.

2 If the amount of the company's profits pool for the scheme as at the beginning of the period is nil, the ring-fenced scheme loss may not be brought into account.

3 If the amount of the company's profits pool for the scheme as at the beginning of the period is—

a greater than nil, and b less than the total of the ring-fenced scheme losses made in the period in relation to the scheme by the company, only the relevant proportion of the ring-fenced scheme loss may be brought into account.

4 For this purpose “ the relevant proportion ” means— A B where— A is the amount of the company's profits pool as at the beginning of the period, and B is the total of the ring-fenced scheme losses made in the period in relation to the scheme by the company.

5 If the amount of the company's profits pool for the scheme as at the beginning of the period is equal to or greater than the total of the ring-fenced scheme losses made in the period in relation to the scheme by the company, the ring-fenced scheme loss may be brought into account in full.

6 A reference in this paragraph to bringing a ring-fenced scheme loss into account is to bringing it into account in determining a debit or credit for the purposes of Part 5 of CTA 2009 (loan relationships) or Part 7 of that Act (derivative contracts).