Corporation Tax Act 2009 section 1217MA

Restriction on use of losses before completion period

Section 1217MA restricts how losses made in a separate theatrical trade before the completion period can be used for tax relief purposes.

• Losses arising in the separate theatrical trade before the completion period cannot be used for general loss relief
• The only permitted use is to carry the loss forward against future profits of the same separate theatrical trade
• Any loss carried forward and deducted in this way is excluded from the corporate loss restriction rules that cap deductions from trading profits
• This ensures theatrical trade losses are ring-fenced until the production is complete, preventing them from sheltering other income