Corporation Tax Act 2010 section 357SE

Artificially inflated claims for additional deduction

Section 357SE extends the anti-avoidance rule on artificially inflated claims for additional deductions so that it also covers the Northern Ireland supplementary deduction.

• The existing anti-avoidance provision in section 1216CL of CTA 2009 targets artificially inflated claims for additional deductions or tax credits in respect of television production.
• Section 357SE ensures that this anti-avoidance rule applies equally to the Northern Ireland supplementary deduction, not just to the standard additional deduction.
• Where arrangements are in place that artificially inflate a claim, HMRC can adjust the amount of the Northern Ireland supplementary deduction accordingly.
• This prevents companies from using contrived arrangements to obtain an unjustifiably large Northern Ireland supplementary deduction on top of the standard television tax relief.