OT21067 - Corporation Tax Ring Fence: Losses and Group Relief: Change in Company Ownership: Introduction
This guidance sets out how HMRC will apply the anti-avoidance rules in CTA10/Part14 to companies carrying on a ring fence trade. Ring fence trades are defined in statute as comprising the oil related activities (CTA10/S274) of a company. Because the scope of a ring fence trade is set in statute, there has been some uncertainty about whether there could be a major change in the nature or conduct of a company鈥檚 ring fence trade. The main guidance on Part 14 (see CTM06300) does not deal with ring fence trades specifically, so this guidance supplements it, to cover the specific situation where a company has a ring fence trade.