Corporation Tax Act 2010 section 357SF

Restriction on use of losses while programme in production

Section 357SF restricts how a Northern Ireland company involved in television production can use its trading losses during the period before the programme is completed, distinguishing between Northern Ireland losses and mainstream losses.

• During production, a Northern Ireland company's pre-completion losses are split into Northern Ireland trade losses and mainstream trade losses, each subject to separate restriction rules.
• Where a company has both Northern Ireland trade losses and mainstream trade profits (or vice versa) in the same pre-completion period, it may claim relief under section 37 to set one against the other.
• Relief for Northern Ireland losses is only available against mainstream profits of the same period, and relief for mainstream losses is only available against Northern Ireland profits of the same period.
• A "pre-completion period" takes the same meaning as defined in section 1216DA of CTA 2009, broadly covering accounting periods during which the programme is still in production.