OT21535 - Corporation tax ring fence: onshore allowance - changes in equity share and the activation of allowance

CTA2010\S356G, S356GA -S356GD

»Ê¹ÚÌåÓýapp above sections apply the principles of S356E activation of allowance, S356EA closing balance of allowance and S356EB carrying forward of unactivated allowance (OT21525) where there has been a change in the equity share of a licensed area containing, in whole or in part, a site.

Where there has been a change (or changes) in equity interest in a particular accounting period then that accounting period is divided into reference periods. A reference period is a period of consecutive days that meets the following conditions:

  1. At the beginning of each day in the period, the company is a licensee in the licensed area;
  2. At the beginning of each day in the period, the company’s share of the equity in the licensed area is the same;
  3. Each day in the period falls within the accounting period.

»Ê¹ÚÌåÓýapp effect is to treat each reference period as an accounting period with an unchanged equity interest. »Ê¹ÚÌåÓýapp main difference is that, for the purposes of activating the allowance, a company’s relevant income from the site in the reference period is (see CTA2010\S356E(3) for accounting periods):

I x R/L

where:

  • I is the company’s relevant income from the site in the whole of the accounting period;
  • R is the number of days in the reference period;
  • L is the number of days in the accounting period for which the company is a licensee in the licensed area concerned.