Corporation Tax Act 2010 section 921

Capital allowances deductions: films

Section 921 deals with the tax treatment of major lump sums received by a lessor who has previously claimed film-related tax deductions in connection with a leased asset, ensuring that any excess amount is brought back into charge as revenue income.

• The section applies where the current lessor has been allowed a film-related tax deduction for expenditure connected with a leased asset, and the major lump sum exceeds the portion already treated as a revenue receipt under the disposal proceeds rules for the original master version of the film.
• A "relevant film deduction" means a deduction claimed either for the allocation of expenditure on master versions of films to accounting periods, or for relief on production or acquisition expenditure in respect of films, both under the Finance (No.2) Act 1992.
• Where the conditions are met, the lessor is treated as having received additional revenue receipts from their trade or business on the relevant occasion.
• The amount of those deemed revenue receipts equals the excess of the major lump sum over the part of that sum already treated as a revenue receipt under the film disposal proceeds rules.