Finance Act 2019 (c. 1)

SCHEDULES

SCHEDULE 15 U.K. Oil activities: transferable tax history

PART 6 U.K. Allocation of activated TTH amount

Allocation of activated TTH to an accounting period U.K.

44 U.K. The total activated TTH amount for a loss period is to be allocated, for the purposes of the application of paragraph 25 in relation to that loss period, to pre-acquisition accounting periods of the purchaser as follows—

• Step 1 Take the most recent pre-acquisition accounting period for which there is an unused transferred profits amount which is greater than nil.

• Step 2 Allocate to that pre-acquisition accounting period an amount equal to the lower of—

  (a)

  the unused transferred profits amount, and

  (b)

  the total activated TTH amount held by the purchaser for the loss period.

• Step 3 Allocate to the next most recent pre-acquisition accounting period an amount equal to the lower of—

  (a)

  the transferred profits amount for that period, and

  (b)

  the available activated TTH amount for the loss period.

• Step 4 Repeat Step 3 (taking later pre-acquisition accounting periods before earlier ones) until the amount given by paragraph (a) or (b) is nil.