# Corporation Tax Act 2010, Section 937F: Ring-fenced scheme losses and relevant scheme profits


(1) Subsection (2) applies if—
(a) a company makes one or more scheme losses in an accounting period in relation to a risk transfer scheme, and
(b) disregarding any profits or losses made otherwise than as a result of the scheme, the relevant group makes a pre-tax economic loss in the period as a result of fluctuations in the scheme rate, index or value.
(2) The relevant proportion of each scheme loss made by the company in the accounting period is a “ring-fenced scheme loss”.
(3) For this purpose “ the relevant proportion ” means—
A–B–CAwhere—
A is the total of the scheme losses made in the period in relation to the scheme by the members of the relevant group,
B is the total of the scheme profits made in the period in relation to the scheme by the members of the relevant group, and
C is the pre-tax economic loss referred to in subsection (1)(b).
(4) Subsection (5) applies if—
(a) a company makes one or more scheme profits in an accounting period in relation to a risk transfer scheme, and
(b) disregarding any profits or losses made otherwise than as a result of the scheme, the relevant group makes a pre-tax economic profit in the period as a result of fluctuations in the scheme rate, index or value.
(5) The relevant proportion of each scheme profit made by the company in the accounting period is a “relevant scheme profit”.
(6) For this purpose “ the relevant proportion ” means—
A–B–CAwhere—
A is the total of the scheme profits made in the period in relation to the scheme by the members of the relevant group,
B is the total of the scheme losses made in the period in relation to the scheme by the members of the relevant group, and
C is the pre-tax economic profit referred to in subsection (4)(b).

---
Source: https://www.legislation.gov.uk/ukpga/2010/4/section/937F (the official version)
Page: https://openlegislation.uk/corporation-tax-act-2010/section-937F
Contains public sector information licensed under the Open Government Licence v3.0. Source: legislation.gov.uk, The National Archives.