# Taxation (International and Other Provisions) Act 2010, Section 205: Provision made or imposed between ring-fence trade and other activities


(1) Subsections (2) to (4) apply if—
(a) a person carries on an oil-related ring-fence trade (see section 206), and
(b) any provision is made or imposed by the person as between—
(i) the oil-related ring-fence trade, and
(ii) any other activities carried on by the person.
(2) Chapters 1 and 3 to 6 (read in accordance with Chapters 2 and 8) apply in relation to the provision as if—
(a) the oil-related ring-fence trade, and the person's other activities, were carried on by two different persons,
(b) the provision were made or imposed as between those two persons by means of a transaction,
(c) those two persons were both controlled by the same person at the time when the provision was made or imposed, and
(d) a potential advantage in relation to United Kingdom taxation were conferred by the provision on each of those two persons.
(3) Subsection (2) has effect subject to subsection (4).
(4) Chapters 1 and 3 to 6 apply in relation to the provision only if the effect of their applying is—
(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
(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.
(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.

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Source: https://www.legislation.gov.uk/ukpga/2010/8/section/205 (the official version)
Page: https://openlegislation.uk/taxation-international-and-other-provisions-act-2010/section-205
Contains public sector information licensed under the Open Government Licence v3.0. Source: legislation.gov.uk, The National Archives.