Corporation Tax Act 2010 section 357NJ

Losses

Section 357NJ confirms that the rules in Part 8B for attributing profits to a company's Northern Ireland Regional Establishment (NIRE) apply equally to the attribution of losses.

• The same attribution rules that apply to profits also apply to losses
• Losses connected with a company's NIRE are attributed using the same methodology as profits
• This ensures consistent treatment of both profits and losses within the Northern Ireland regime
• No separate or additional rules are needed for loss attribution — the profit attribution framework is simply extended