Corporation Tax Act 2009 section 1217SB

Use of losses in the completion period

Section 1217SB sets out how losses arising in the separate orchestral trade are treated during the completion period, and in particular how the portion of any loss attributable to orchestra tax relief is ring-fenced from wider use.

• Losses carried forward to the completion period can only be set against total profits or surrendered as group relief to the extent they are not attributable to orchestra tax relief
• Losses arising in the completion period itself are similarly restricted — only the non-orchestra-tax-relief element may be deducted from total profits or surrendered as group relief
• The orchestra tax relief element of a loss is calculated by working out what the loss would have been without the additional deduction available under Chapter 3, and subtracting that figure from the actual total loss
• These restrictions do not apply to terminal losses dealt with under section 1217SC