Corporation Tax Act 2010 section 357L

Northern Ireland regional establishments of companies

Section 357L defines when a company is considered to have a Northern Ireland regional establishment (NIRE), which is relevant to determining whether its trading profits may be taxed at the Northern Ireland rate of corporation tax.

• A company has a NIRE if it operates wholly or partly through a fixed place of business in Northern Ireland, such as an office, branch, factory, workshop, mine, or construction site.
• A company also has a NIRE if a dependent agent based in Northern Ireland habitually exercises authority to conduct business on the company's behalf.
• The definition of "fixed place of business" is broad and includes management locations, natural resource exploration installations, quarries, oil or gas wells, and building or installation projects.
• The NIRE definition is subject to further qualifications in sections 357LA (dealing with agents of independent status) and 357LB (dealing with alternative finance arrangements).