What does section 1217O of the Corporation Tax Act 2009 do?

Section 1217O grants the Treasury a regulation-making power to amend the definitions of 'core expenditure' (section 1217GC) and 'costs of production' (section 1217IC) for theatrical productions. The Treasury can specify which activities should or should not count as part of developing, producing, running or closing a production for tax relief purposes.

Can the Treasury apply section 1217O to specific types of theatrical production only?

Yes, the power under section 1217O is flexible. The Treasury can make regulations that apply to all theatrical productions generally or only to theatrical productions of a particular description. This allows tailored rules for different production types without requiring primary legislation to be enacted.

How does section 1217O affect the calculation of theatrical productions tax relief?

Section 1217O enables the Treasury to broaden or narrow the activities that qualify as core expenditure or costs of production. By clarifying which activities count, the regulations directly affect the amount of theatrical productions tax relief a production company can claim under the Corporation Tax Act 2009.

Can the Treasury use section 1217O to address new types of production activity?

Yes. If new activities arise, such as digital audience engagement during production development, the Treasury can make regulations under section 1217O to clarify whether those activities qualify. This ensures the tax relief framework remains current and reflects how theatrical productions are actually developed and staged.

Corporation Tax Act 2009 section 1217O

Activities involved in developing, producing, running or closing a production

Section 1217O gives the Treasury the power to amend the definitions of what counts as core expenditure or costs of production for theatrical productions, by specifying which activities should or should not be included.

The Treasury can make regulations to change the meaning of "core expenditure" and "costs of production" for theatrical productions
Regulations can specify that particular activities are, or are not, to be treated as part of developing, producing, running or closing a production
The power applies to theatrical productions generally or to specific types of theatrical production
This ensures the tax relief framework can be updated to reflect changes in how theatrical productions are developed and staged

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