SCHEDULES

SCHEDULE 15Oil activities: transferable tax history

PART 6Allocation of activated TTH amount

44Allocation of activated TTH to an accounting period

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—

    1. a

      the unused transferred profits amount, and

    2. 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—

    1. a

      the transferred profits amount for that period, and

    2. 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.