OT16270 - PRT: allowable losses - unrelievable field losses - associated party claims
If the participator is a company, a UFL may be claimed by a company associated with the participator company which incurred the loss. For UFL purposes ‘associationâ€� is defined in the same terms used in OTA75\S5(7) and OTA75\S5(8) for abortive exploration expenditure and in OTA75\S5A(4) for exploration and appraisal expenditure, see OT13810. »Ê¹ÚÌåÓýapp requirement is that throughout the part of the ‘relevant periodâ€� in which both companies were in existence, one was the ultimate 51% parent of the other or both had the same ultimate 51% parent. »Ê¹ÚÌåÓýapp relevant period runs:
- from the beginning of the chargeable period in which the loss accrued until the end of that period or, if later,
- until the end of the first chargeable period in which the claimant company is a participator in the field against the profits of which relief is sought.