Corporation Tax Act 2010 section 357UF

Restriction on use of losses before completion period

Section 357UF modifies the rules on pre-completion period losses for theatrical productions where the production company is a Northern Ireland company, requiring losses to be split into Northern Ireland and mainstream categories and limiting how those losses can be offset against profits.

• Pre-completion losses in a theatrical trade must be separated into Northern Ireland losses and mainstream losses where the company is a Northern Ireland company
• Where a Northern Ireland company has Northern Ireland losses alongside mainstream profits (or vice versa) in a pre-completion period, it may claim relief under section 37
• Northern Ireland losses can only be relieved against mainstream profits of the same period, and mainstream losses can only be relieved against Northern Ireland profits of the same period
• The completion period takes the same meaning as defined for theatrical productions in section 1217MA of CTA 2009