OT30450 - Capital Gains

Ring Fence Extension TCGA 92\s197 and s198.

FA84 introduced provisions now at TCGA92\s197 extending ring fence profits to include certain gains arising from UK and UKCS oil fields and related assets.

FA84 also introduced the ring fence rollover provisions, now TGCA92\s198. There would have been little point ring fencing gains if they could be rolled over against non ring fence assets.

The basic concept of TGCA92\s197 is that gains and losses from disposals of interests in fields (and certain assets) are aggregated to form a single gain or loss. A resulting gain is completely within the ring fence; a resulting loss is within the ring fence unless the taxpayer elects within 2 years for it not to be.