OT21069A - Corporation Tax Ring Fence: Losses and Group Relief: Change in Company Ownership: Marginal cases

It is unusual for HMRC to consider running a CTA10/S673 argument in the context of a company’s ring fence trade. The application of CTA10/S673 is very much dependent on the facts of the case. If you consider that OTA10/S673 could apply, you should contact the Oil and Gas tax policy and technical team in BAI.