Corporation Tax Act 2009 section 1217SA

Restriction on use of losses before completion period

Section 1217SA restricts how a company can use losses arising in its separate orchestral trade during accounting periods before the completion period.

• Losses made in the separate orchestral trade before the completion period cannot be used for general loss relief
• The only permitted use is to carry the loss forward and set it against future profits of the same separate orchestral trade
• Any loss carried forward and deducted in this way is ignored when calculating the corporate loss restriction (the cap on deductions from trading profits)
• This ensures orchestral trade losses are ring-fenced within that trade until the production reaches its completion period