Corporation Tax Act 2010 section 357UY

Terminal losses

Section 357UY modifies the treatment of terminal losses under the exhibition tax relief rules when those losses qualify as Northern Ireland losses, ensuring they retain their Northern Ireland character when carried forward.

• When a company ceases an exhibition trade and has a terminal loss that is a Northern Ireland loss, special rules apply to preserve the Northern Ireland status of that loss.
• If the company elects to treat all or part of a terminal loss as a loss brought forward of a different trade it carries on, and the terminal loss is a Northern Ireland loss, it is treated as a Northern Ireland loss brought forward rather than a general loss brought forward.
• Similarly, if the company claims to transfer all or part of a terminal loss so that it is treated as a loss brought forward by a different company, and the terminal loss is a Northern Ireland loss, it is again treated as a Northern Ireland loss brought forward in the hands of the recipient company.
• This ensures that Northern Ireland terminal losses do not lose their special status when redirected to another trade or transferred to another company, preserving eligibility for the lower Northern Ireland corporation tax rate.