»Ê¹ÚÌåÓýapp

Example 1

Ìý	CP	Profit\(Loss)	Oil Allowance	PRT
Company X	CP1	(20)	0	Ìý
Ìý	CP2	30	10	0
Ìý	CP3	40	40	0
Ìý	CP4	10	10	0
Company Y	CP5	10	10	0
Ìý	CP6	(80)	0	Ìý

»Ê¹ÚÌåÓýapp transfer from X to Y is completed after 7 March 2001 and is subject to a successful FA80\SCH17\PARA4 disapplication. Under the old rules Y’s UFL would have been 70. Its CP6 loss would only have been reduced by 10 under OTA75\S7(3). But under FA01\SCH32, its UFL is reduced to 10 after taking account of X’s relevant profits of 60.

Example 2

»Ê¹ÚÌåÓýapp facts are the same as in Example 1 except that in CP3 X’s profits of 40 are calculated after the allowance of a claim under OTA75\S5B (research) of 5. »Ê¹ÚÌåÓýapp 5 is ‘unrelated field expenditureâ€� and needs to be ‘added backâ€� to arrive at X’s relevant profits. X’s relevant profits therefore become 65 and Y’s UFL is accordingly reduced to 5 (70-65).

Example 3

»Ê¹ÚÌåÓýapp facts are the same as in Example 1 except that X transfers only 50% of its interest to Y with the balance being transferred to another company, Z. In calculating Y’s UFL, FA01\SCH32\PARA8(3) means that only 50% of X’s relevant profits (‘the corresponding partâ€�) need to be taken into account. »Ê¹ÚÌåÓýapp UFL is therefore 40 (70-30).

Example 4

Ìý	CP	Profit\(Loss)	Oil Allowance	PRT
Company X	CP1	(50)	0	Ìý
Company Y	CP2	10	10	0
Ìý	CP3	20	20	0
Ìý	CP4	10	10	0
Ìý	CP5	10	10	0
Company Z	CP6	(50)	0	Ìý

Both transfers are completed after 7 March 2001 and are subject to successful disapplications under FA80\Sch17\ParaA4. Under the old rules, both X and Z would have been able to claim UFLs of 50. But the UFL that would have arisen had there been no transfers of the interest would have been 50 (combined losses of 100 less relevant profits of 50). Under FA01\Sch32\Para10(1) Z’s UFL remains 50, but X’s UFL is reduced to 0. X’s loss is offset in priority to Z’s as it accrued at an earlier time.

Example 5

Ìý	CP	Profit\(Loss)	Oil Allowance	PRT
Company X	CPs1-8	30	30	0
Company Y	CP9	10	0	0
Company Z	CP10	(50)	0	Ìý

Both transfers are completed after 7 March 2001.»Ê¹ÚÌåÓýapp XY transfer is subject to a successful FA80\Sch17\Para4 disapplication, but the YZ transfer is within FA80\Sch17 Parts II and III.

Under the old rules, Z’s UFL would have been 40 after taking into account the necessary carry back of 10 under FA80\Sch17\Para15 to cover Y’s assessable profits. But, although Z itself has not been party to an excluded transfer, its loss is still within FA01\Sch32. »Ê¹ÚÌåÓýappre is an ‘excluded transferâ€� between X and Y (FA01\Sch32\Para1(1)(b)) and Z is a ‘subsequent new ownerâ€� (FA01\Sch32\Para1(1)(c)). Z’s UFL is therefore reduced to 10 (50-10-30), the UFL which would have been claimable had there been no field transfers.