Page 24 - PowerPoint Presentation

Ring Fencing

• Losses are ring fenced if:

• If in out of the 5 preceding years the taxpayer made losses in 3

years.

• There are from suspect trades.

• What is a suspect trade?

• Ring fencing applies to taxpayers within the higher tax bracket.

• Ring fencing effectively means that the losses from other

trades are not deducted from other trades and as a result they
can only be deducted from that specific trade.

• Escape clause (facts and circumstances).

• The “six-out-of-ten-years” requirement (the “catch all”

provision)

• Ring fencing on apply to a taxpayer who is a natural person.

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