OT22014 - Interest and Financing

OTO Commentary. Section 494(4). charges not allowed against ring fence profits

Charges (for accounting periods ending on or after 1st April 1996 this will exclude all forms of interest) which cannot be allowed against ring fence profits as a result of S494 remain allowable against non ring fence profits. An excess of unrelievable charges may be surrendered as group relief. This subsection disapplies the restriction in ICTA88/s403(7). In other words, charges that are not allowed within the ring fence are not debarred from group relief merely because some ring fence profits remain uncovered.