Corporation Tax Act 2010 section 357QG

Carrying forward of production losses

Section 357QG explains how production losses from a film, television or video game trade are carried forward when a Northern Ireland company has both Northern Ireland and mainstream streams of income within that trade during a pre-completion period.

• During pre-completion periods for film, television or video game productions, losses from the separate creative trade can be carried forward under the normal audio-visual rules, but with the Northern Ireland regime applied on top.
• Any loss carried forward must be identified as either a Northern Ireland loss or a mainstream loss, and the carry-forward rules operate separately for each stream.
• Where a company has Northern Ireland losses alongside mainstream profits (or mainstream losses alongside Northern Ireland profits) in the same period, it may claim cross-stream relief despite the normal restriction on using pre-completion losses.
• This cross-stream relief is given under the general trade loss relief rules (relief against total profits), allowing losses from one stream to be set against profits of the other stream within the same accounting period.