Corporation Tax Act 2009 section 1217F

Overview of Part

Section 1217F provides an overview of the tax relief regime for production companies in respect of their theatrical productions, covering the scope and structure of Part 15C.

• Part 15C provides tax relief for production companies in respect of theatrical productions, defining key terms and setting out qualifying conditions
• Relief takes two forms: additional deductions against taxable profits for qualifying expenditure, and theatre tax credits received as cash payments in exchange for surrendering losses
• A company claiming relief is treated as carrying on a separate trade for the theatrical production, with specific rules for calculating profits, losses, and terminal losses
• Anti-avoidance provisions apply to tax avoidance arrangements or arrangements not entered into for genuine commercial reasons, and relief given before the trade ceases is treated as provisional and may be clawed back