Corporation Tax Act 2010 section 357QB

Tax credit: entitlement

Section 357QB sets out special rules for calculating qualifying land remediation losses for Northern Ireland companies, replacing the standard rules that would otherwise apply under CTA 2009.

• Northern Ireland companies carrying on a qualifying trade use different rules from the standard CTA 2009 provisions when determining qualifying land remediation losses
• A qualifying land remediation loss arises where a company obtains an additional deduction for land remediation expenditure and has either a Northern Ireland trade loss or a mainstream trade loss in the period
• The loss is capped at the lower of the unrelieved trade loss and the relevant qualifying expenditure multiplied by an appropriate percentage, with different percentages applying to Northern Ireland and mainstream losses
• The adjusted percentage for Northern Ireland losses uses a formula — 100 + (A × (MR / NIR)) — which recalibrates the standard percentage to reflect the ratio between the main corporation tax rate and the Northern Ireland rate