Corporation Tax Act 2010
Sections and provisions with full text and the judgments that cite each one.
Section 356NB — Restriction on debits to be brought into account
Restriction on debits to be brought into account 356NB 1 Debits may not be brought into account for the purposes of Part 5 of CTA 2009 (loan relationships) in respect of the contractor's loan…
Section 356OB — Disposals of land in the United Kingdom
Disposals of land in the United Kingdom 356OB 1 Section 356OC(1) applies (subject to subsection (3) of that section) if— a a person within subsection (2)(a), (b) or (c) realises a profit or gain from…
Section 356BC — “Site”
“Site” 356BC In this Chapter “site” (except in the expression “ drilling and extraction site ”) means— a a drilling and extraction site that is not used in connection with any oil field, or b an oil…
Section 356C — Generation of onshore allowance
Generation of onshore allowance 356C 1 Subsection (2) applies where a company incurs any relievable capital expenditure in relation to a qualifying site. 2 The company is to hold an amount of…
Section 356GC — Carry-forward of unactivated allowance from a reference period
Carry-forward of unactivated allowance from a reference period 356GC 1 If, in the case of a reference period (“RP1”) of a company, the amount mentioned in subsection (1)(b) of section 356GB exceeds…
Section 356JC — Overview
Overview 356JC 1 This Chapter sets out how relief for certain expenditure incurred in relation to a cluster area is given by way of reduction of a company's adjusted ring fence profits. 2 The Chapter…
Section 356LC — “Lease”
“Lease” 356LC In this Part “ lease ” has the meaning given by section 868 and “leased” and “leasing” are to be construed accordingly.
Section 356NC — Restriction on credits to be brought into account
Restriction on credits to be brought into account 356NC 1 Credits in respect of exchange gains from the contractor's loan relationships may not be brought into account for the purposes of Part 5 of…
Section 356OC — Disposals of land: profits treated as trading profits
Disposals of land: profits treated as trading profits 356OC 1 The profit or gain is to be treated for corporation tax purposes as profits of a trade carried on by the chargeable company (see section…
Section 356D — Reduction of adjusted ring fence profits
Reduction of adjusted ring fence profits 356D 1 A company's adjusted ring fence profits for an accounting period are to be reduced by the cumulative total amount of activated allowance for the…
Section 356GD — Unactivated amounts attributable to a reference period
Unactivated amounts attributable to a reference period 356GD 1 For the purposes of section 356GB(1)(b), the total amount of unactivated allowance attributable to a reference period and a site is— P +…
Section 356JD — Meaning of “cluster area”
Meaning of “cluster area” 356JD 1 In this Part “ cluster area ” means an offshore area which the OGA determines to be a cluster area. 2 A cluster area is treated as not including any previously…
Section 356LD — “Contractor's ring fence profits”
“Contractor's ring fence profits” 356LD In this Part the “ contractor's ring fence profits ”, in relation to an accounting period, means the contractor's income arising from oil contractor activities…
Section 356ND — Management expenses
Management expenses 356ND No deduction under section 1219 of CTA 2009 (expenses of management of a company's investment business) is to be allowed from the contractor's ring fence profits.
Section 356OD — Disposals of property deriving its value from land in the United Kingdom
Disposals of property deriving its value from land in the United Kingdom 356OD 1 Section 356OE applies (subject to subsection (3) of that section) if— a a person realises a profit or gain from a…
Section 356E — Activation of allowance: no change of equity share
Activation of allowance: no change of equity share 356E 1 This section applies where— a a company is a licensee in a licensed area for the whole or part (“the licensed part”) of an accounting period,…
Section 356JE — Meaning of “investment expenditure”
Meaning of “investment expenditure” 356JE 1 For the purposes of this Chapter, expenditure incurred by a company is “investment” expenditure only if it is— a capital expenditure, or b expenditure of…
Section 356NE — Losses
Losses 356NE 1 Relief in respect of a loss incurred by the contractor (or an amount of such a loss) may not be given under section 37 (relief for trade losses against total profits) or section 45A…
Section 356OE — Disposals within section 356OD: profits treated as trading profits
Disposals within section 356OD: profits treated as trading profits 356OE 1 The relevant amount is to be treated for corporation tax purposes as profits of a trade carried on by the chargeable…
Section 356F — Transfer of allowances between sites
Transfer of allowances between sites 356F 1 This section applies if a company has, with respect to a site, an amount (“N”) of onshore allowance available to carry forward to an accounting period— a…
Section 356JF — Generation of cluster area allowance
Generation of cluster area allowance 356JF 1 Subsection (2) applies where a company— a is a licensee in a licensed area or sub-area which is wholly or partly included in a cluster area, and b incurs…
Section 356NF — Group relief and group relief for carried-forward losses
Group relief and group relief for carried-forward losses 356NF 1 On a claim for group relief made by a claimant company in relation to a surrendering company, group relief may not be allowed against…
Section 356OF — Profits and losses
Profits and losses 356OF 1 Sections 356OB to 356OE have effect as if they included provision about losses corresponding to the provision they make about profits and gains. 2 Accordingly, in the…
Section 356G — Introduction to sections 356GA to 356GD
Introduction to sections 356GA to 356GD 356G 1 Sections 356GA to 356GD apply to a company in respect of an accounting period and a licensed area that is or contains a site, if the following…
Section 356JG — Reduction of adjusted ring fence profits
Reduction of adjusted ring fence profits 356JG 1 A company's adjusted ring fence profits for an accounting period are to be reduced by the cumulative total amount of activated allowance for the…
Section 356NG — Capital allowances
Capital allowances 356NG A capital allowance may not to any extent be given effect under section 259 or 260 of CAA 2001 (special leasing) by deduction from the contractor's ring fence profits.
Section 356OG — The chargeable company
The chargeable company 356OG 1 For the purposes of sections 356OC and 356OE the general rule is that the “chargeable company” is the company (“C”) that realises the profit or gain (as mentioned in…
Section 356H — Introduction to sections 356HA and 356HB
Introduction to sections 356HA and 356HB 356H 1 Sections 356HA and 356HB apply where a company (“ the transferor ”)— a disposes of the whole or part of its share of the equity in a licensed area that…
Section 356JH — Activation of allowance: no change of equity share
Activation of allowance: no change of equity share 356JH 1 This section applies where— a for the whole or part of an accounting period, a company is a licensee in a licensed area or sub-area which is…
Section 356NH — Restriction on deductions from contractor's ring fence profits
Restriction on deductions from contractor's ring fence profits 356NH 1 For the purpose of determining the contractor's taxable total profits for an accounting period, the sum of any relevant…
Section 356OH — Fragmented activities
Fragmented activities 356OH 1 Subsection (3) applies if— a a company (“C”) disposes of any land in the United Kingdom, b any of conditions A to D in section 356OB is met in relation to the land, and…
Section 356I — Adjustments
Adjustments 356I 1 This section applies if there is any alteration in a company's adjusted ring fence profits for an accounting period after this Chapter has effect in relation to the profits. 2 Any…
Section 356JI — Reference periods
Reference periods 356JI 1 This section applies where— a a company is a licensee for the whole or part of an accounting period in one or more licensed areas or sub-areas (“the relevant areas”) which…
Section 356NI — Deductions allowances where company has contractor's ring fence profits
Deductions allowances where company has contractor's ring fence profits 356NI 1 This section applies if a company (“C”) has contractor's ring fence profits for an accounting period. 2 Subsections (3)…
Section 356OI — Calculation of profit or gain on disposal
Calculation of profit or gain on disposal 356OI For the purposes of this Part, the profit or gain (if any) from a disposal of any property is to be calculated according to the principles applicable…
Section 356J — “Authorisation of development”: drilling and extraction sites
“Authorisation of development”: drilling and extraction sites 356J 1 References in this Chapter to authorisation of development of a site are to be interpreted as follows in relation to a drilling…
Section 356JJ — Activation of allowance: reference periods
Activation of allowance: reference periods 356JJ 1 The amount (if any) of activated allowance that a company has for a cluster area for a reference period is the smaller of the following— a the…
Section 356NJ — Modification of provisions restricting the use of losses
Modification of provisions restricting the use of losses 356NJ 1 The following deductions are to be treated as not being relevant deductions for the purposes of section 269ZD (restrictions on…
Section 356OJ — Apportionments
Apportionments 356OJ Any apportionment (whether of expenditure, consideration or any other amount) that is required to be made for the purposes of this Part is to be made on a just and reasonable…
Section 356JK — Disposal of equity share: transfer of allowance
Disposal of equity share: transfer of allowance 356JK 1 Subsections (2) and (3) apply where— a a company (“ the transferor ”) makes a disposal, on the day following the end of an accounting period or…
Section 356K — Overview of Part
Overview of Part 356K 1 This Part is about the corporation tax treatment of oil contractor activities. 2 Chapter 2 contains basic definitions used in this Part. 3 Chapter 3 treats oil contractor…
Section 356OK — Arrangements for avoiding tax
Arrangements for avoiding tax 356OK 1 Subsection (3) applies if an arrangement has been entered into the main purpose or one of the main purposes of which is to enable a company to obtain a relevant…
Section 356JL — Use of allowance attributable to unlicensed area
Use of allowance attributable to unlicensed area 356JL 1 Subsection (2) applies where— a a company (“C”) disposes of the whole or part of its share of the equity in a licensed area or sub-area (“area…
Section 356L — “Oil contractor activities” etc
“Oil contractor activities” etc 356L 1 The definitions in this section have effect for the purposes of this Part. 2 “ Oil contractor activities ” means activities carried on by a company (“the…
Section 356OL — Profits attributable to period before relevant activities etc began
Profits attributable to period before relevant activities etc began 356OL 1 Subsection (2) applies if— a subsection (1) of section 356OC applies because Condition D in section 356OB is met (land…
Section 356JM — Adjustments
Adjustments 356JM 1 This section applies if there is any alteration in a company's adjusted ring fence profits for an accounting period after this Chapter has effect in relation to the profits. 2 Any…
Section 356M — Oil contractor activities treated as separate trade
Oil contractor activities treated as separate trade 356M If the contractor carries on oil contractor activities as part of a trade, those activities are treated for the purposes of the charge to…
Section 356OM — Tracing value
Tracing value 356OM 1 This section applies if it is necessary to determine the extent to which the value of any property or right is derived from any other property or right for the purposes of this…
Section 356JN — When capital expenditure is incurred
When capital expenditure is incurred 356JN 1 Section 5 of CAA 2001 (when capital expenditure is incurred) applies for the purposes of this Chapter as for the purposes of that Act. 2 Regulations under…
Section 356N — Restriction on hire etc of relevant assets to be brought into account
Restriction on hire etc of relevant assets to be brought into account 356N 1 This section applies if the contractor makes, or is to make, one or more payments under a lease of— a a relevant asset, or…