Corporation Tax Act 2009 section 1217MB

Use of losses in the completion period

Section 1217MB sets out how losses from a separate theatrical trade are treated during the completion period, particularly restricting the use of losses that arise from the additional tax deduction available for theatrical productions.

• Losses carried forward to the completion period may be set against total profits or surrendered as group relief, but only to the extent they are not attributable to the additional theatrical production deduction
• Losses arising in the completion period itself are similarly restricted — only the portion not caused by the additional deduction can be offset against total profits or surrendered as group relief
• The portion of a loss attributable to the additional deduction is calculated by working out what the loss would have been without the deduction, then subtracting that figure from the total loss
• These restrictions do not apply to terminal losses, which are dealt with separately under section 1217MC