Corporation Tax Act 2010 section 357OC

Northern Ireland intangibles credits and debits: SMEs that are not Northern Ireland employers and large companies

Section 357OC sets out how to determine the Northern Ireland intangibles credits and debits for companies that qualify as Northern Ireland companies under either the SME (election) condition or the large company condition.

• This section applies to companies that are Northern Ireland companies by virtue of the SME (election) condition or the large company condition, and uses the separate enterprise principle to identify which intangible fixed asset credits and debits are attributable to the company's Northern Ireland Regional Establishment (NIRE)
• Northern Ireland intangibles credits are those trade receipts from intangible fixed assets that are attributable to the NIRE, excluding credits relating to pre-commencement assets, excluded activities, and realisation credits (though the Northern Ireland element of realisation credits is added back separately)
• Northern Ireland intangibles debits are those trade expenses from intangible fixed assets that are attributable to the NIRE, excluding debits relating to pre-commencement assets, excluded activities, and realisation debits (though the Northern Ireland element of realisation debits is added back separately)
• Key defined terms — pre-commencement asset, realisation credit, realisation debit, and the Northern Ireland element of each — are defined in separate sections (357OH, 357OD, and 357OE) and are essential to applying this provision correctly