Corporation Tax Act 2010 section 357OB

Northern Ireland intangibles credits and debits: SMEs that are Northern Ireland employers

Section 357OB sets out how to determine the intangible fixed asset credits and debits that qualify for the Northern Ireland corporation tax rate for small and medium-sized enterprises (SMEs) that are Northern Ireland employers carrying on a qualifying trade.

• Applies to SMEs that qualify as Northern Ireland companies under the Northern Ireland employer condition and carry on a qualifying trade (i.e. one that is not an excluded trade)
• Intangible fixed asset credits and debits of the qualifying trade are generally included as Northern Ireland amounts, but credits and debits relating to pre-commencement assets are excluded, and realisation credits and debits are replaced by their Northern Ireland element only
• Where the company also carries on an excluded activity within the trade, any credits or debits attributable to assets held for the purposes of that excluded activity are stripped out of the Northern Ireland amounts
• The Northern Ireland element of realisation credits and debits is always included regardless of whether the company carries on an excluded activity