Corporation Tax Act 2010 section 357NA

Northern Ireland profits or losses and mainstream profits or losses

Section 357NA explains how to divide a qualifying trade's profits or losses between Northern Ireland profits or losses (potentially taxable at the Northern Ireland rate) and mainstream profits or losses (taxable at the main UK corporation tax rate), for companies that meet the large company condition or the SME (election) condition.

• Profits or losses of a qualifying trade are Northern Ireland profits or losses if they do not arise from an excluded activity, arise through or from the company's Northern Ireland Regional Establishment (NIRE), and are attributable to that NIRE.
• Where a trade is an excluded trade but has back-office activities carried on through a NIRE, any profits imputed as Northern Ireland back-office profits are treated as Northern Ireland profits.
• Any profits or losses that do not qualify as Northern Ireland profits or losses are treated as mainstream profits or losses, taxable at the main UK rate.
• Detailed rules for determining the amount of profits or losses attributable to a NIRE are set out in sections 357NC to 357NI, and section 357LJ provides for certain investment manager profits to be disregarded.