{
  "url": "https://openlegislation.uk/taxation-international-and-other-provisions-act-2010/section-205",
  "json_url": "https://openlegislation.uk/taxation-international-and-other-provisions-act-2010/section-205.json",
  "legislation": "ukpga/2010/8",
  "legislation_title": "Taxation (International and Other Provisions) Act 2010",
  "legislation_url": "https://openlegislation.uk/taxation-international-and-other-provisions-act-2010",
  "path": "section/205",
  "kind": "section",
  "number": "205",
  "heading": "Provision made or imposed between ring-fence trade and other activities",
  "text": "(1) Subsections (2) to (4) apply if—\n(a) a person carries on an oil-related ring-fence trade (see section 206), and\n(b) any provision is made or imposed by the person as between—\n(i) the oil-related ring-fence trade, and\n(ii) any other activities carried on by the person.\n(2) Chapters 1 and 3 to 6 (read in accordance with Chapters 2 and 8) apply in relation to the provision as if—\n(a) the oil-related ring-fence trade, and the person's other activities, were carried on by two different persons,\n(b) the provision were made or imposed as between those two persons by means of a transaction,\n(c) those two persons were both controlled by the same person at the time when the provision was made or imposed, and\n(d) a potential advantage in relation to United Kingdom taxation were conferred by the provision on each of those two persons.\n(3) Subsection (2) has effect subject to subsection (4).\n(4) Chapters 1 and 3 to 6 apply in relation to the provision only if the effect of their applying is—\n(a) that a larger amount is taken for tax purposes to be the amount of the profits of the oil-related ring-fence trade for any chargeable period, or\n(b) that a smaller amount (including nil) is taken for tax purposes to be the amount for any chargeable period of any losses of the oil-related ring-fence trade.\n(5) In subsection (4)(a), the reference to a larger amount includes, if there would not otherwise have been profits, an amount of more than nil.",
  "extent": null,
  "status": null,
  "version": "current",
  "annotations": [],
  "outstanding_effects": [],
  "provenance": {
    "source": "legislation.gov.uk",
    "source_url": "https://www.legislation.gov.uk/ukpga/2010/8/section/205",
    "retrieved_at": "2026-10-29T09:10:17.008829+00:00"
  },
  "licence": "Open Government Licence v3.0",
  "licence_url": "https://www.nationalarchives.gov.uk/doc/open-government-licence/version/3/",
  "attribution": "Contains public sector information licensed under the Open Government Licence v3.0. Source: legislation.gov.uk, The National Archives."
}