Page 43 - Taxation F6
P. 43

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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