Corporation Tax Act 2010 section 357QH

Transfer of terminal loss

Section 357QH ensures that when a Northern Ireland company's separate production trade ceases and a terminal loss is transferred under the creative industry rules, the Northern Ireland status of that loss is preserved.

• This section applies when a Northern Ireland company stops carrying on a separate production trade during an accounting period.
• The cessation must trigger the terminal loss transfer rules under section 1179BG of the Corporation Tax Act 2009, which allow unused losses to be transferred to another qualifying production or group company.
• The transferable amount must represent a Northern Ireland loss — that is, a loss arising from the Northern Ireland aspects of the trade.
• Where these conditions are met, any references in the transfer rules to a "loss" are read as references to a "Northern Ireland loss", ensuring the special Northern Ireland tax treatment follows the loss to its new home.