Corporation Tax Act 2010 section 356GC

Carry-forward of unactivated allowance from a reference period

Section 356GC deals with what happens when a company does not use all of its onshore allowance in a given reference period, allowing the unused portion to be carried forward to the next period.

• If a company's onshore allowance for a reference period exceeds the adjusted ring fence profits for that period, the unused balance carries forward.
• The amount carried forward equals the difference between the available allowance and the adjusted ring fence profits.
• If the reference period is immediately followed by another reference period for the same site, the unused allowance carries into that next reference period.
• If there is no immediately following reference period for the same site, the unused allowance instead carries forward into the company's next accounting period.