Corporation Tax Act 2010 section 357SH

Terminal losses

Section 357SH explains how the terminal loss rules for television production companies interact with the Northern Ireland corporation tax regime, ensuring that Northern Ireland terminal losses retain their Northern Ireland character when carried forward or transferred.

• This section applies the terminal loss provisions of section 1216DC of CTA 2009 within the Northern Ireland tax regime.
• Where a company elects to reclassify all or part of a terminal loss as a loss carried forward from a different trade, and the terminal loss relates to Northern Ireland, the reclassified loss retains its status as a Northern Ireland loss.
• Similarly, where a company claims to treat all or part of a terminal loss as a loss brought forward by a different company, a Northern Ireland terminal loss will continue to be treated as a Northern Ireland loss brought forward.
• The purpose of the section is to preserve the Northern Ireland designation of terminal losses so that the correct tax treatment is maintained when those losses are reallocated or transferred.