Corporation Tax Act 2010 section 357NB

Profit imputed to Northern Ireland back-office activities

Section 357NB sets out how to calculate the Northern Ireland profits attributable to back-office activities carried on in Northern Ireland, where a trade is an excluded trade that qualifies solely because of those back-office activities.

• Northern Ireland back-office profits are calculated by multiplying each qualifying back-office deduction by a relevant percentage (currently 5%) and adding the results together.
• A Northern Ireland back-office deduction is any deduction the company can claim in computing its trading profits for the period, provided it relates to back-office activities carried on in Northern Ireland.
• The Treasury has the power to change the 5% figure by regulations, and those regulations may set different percentages for different trades or different types of back-office activity.
• This calculation feeds into the broader framework under section 357NA(3) for determining which portion of a company's trading profits is taxed at the Northern Ireland rate of corporation tax.