Corporation Tax Act 2010 section 356G

Introduction to sections 356GA to 356GD

Section 356G introduces the rules in sections 356GA to 356GD, which deal with how the onshore allowance works when a company's share of equity in a licensed area changes during an accounting period.

• These rules apply where a company is a licensee in a licensed area (that is or contains a site) for all or part of an accounting period, and its equity share changes during that period.
• The company must hold different shares of equity (each greater than zero) at different times within the same accounting period for the rules to be triggered.
• Sections 356GA to 356GD divide the accounting period into reference periods, each reflecting a time when the company held a particular equity share, and determine how onshore allowance is activated for each reference period.
• Where a company's equity share changes more than once in a single day (i.e. it holds three or more different shares during that day), the rules apply with any necessary modifications.