OT21040 - Corporation Tax Ring Fence and Supplementary Charge
Ring Fence Tariff Receipts
Tariff receipts and tax-exempt tariffing receipts (
OT15810) which would not otherwise be
within the ring fence are brought in by ICTA 88/s496(1). Tariff
receipts and tax-exempt tariffing receipts are considered in detail
in the PRT section of this manual to which reference should be made
for background information. In view of the coverage in the PRT
section the nature and character of tariffs is not discussed in any
detail at this point.
A few additional notes may be useful.
- for income to be within s496 it must also be within the charge to PRT. Where this is not so, then tariff receipts and tax-exempt tariffing receipts can still be within the RF if they fall within the various definitions.
- where a company is connected with a participator and receives tariff receipts or tax- exempt tariffing receipts, which for PRT purposes are attributable to the participator, the tariffing activity iswithin the ring fence. (ICTA 1988/s496(2)).
- where tariff receipts or tax-exempt tariffing receipts are received by a participator in a foreign (e.g. Norwegian) field for UK use of a field asset, these are within PRT and are brought within the ring fence by OTA83/sch4/para16
- in certain circumstances where the chargeable field for tariff income for PRT purposes would otherwise change FA99/S98 deems the recipient to remain or to become a participator in the PRT field ( OT15150).The recipient is then also deemed to be a participator in the PRT field for the purposes of ICTA 88/s496 and other relevant sections.
