Corporation Tax Act 2009 section 1209

Restriction on use of losses while film in production

Section 1209 restricts how a film production company can use trading losses that arise during accounting periods before the film is completed or abandoned.

• Losses from a single film trade incurred before the film is completed or abandoned ("pre-completion losses") face restrictions on how they can be relieved.
• These pre-completion losses can only be carried forward and set against future profits of the same film trade — they cannot be offset sideways against other profits or surrendered as group relief.
• Where such losses are carried forward and used against profits of the same film trade, they are excluded from the corporate loss restriction rules in section 269ZB of CTA 2010.
• Once the film is completed or abandoned, section 1210 may allow some or all of those previously restricted losses to be used more broadly.