Corporation Tax Act 2010 section 357H

Introduction

Section 357H introduces Part 8B of the Corporation Tax Act 2010, which establishes a separate Northern Ireland rate of corporation tax and sets out the framework for determining which profits qualify for that rate.

• Part 8B creates a distinct Northern Ireland corporation tax rate that applies to qualifying "Northern Ireland profits" of eligible companies, with detailed rules for how the rate is determined and applied.
• Key definitions — including "Northern Ireland company", "qualifying trade", "SME", "Northern Ireland employer" and "Northern Ireland regional establishment" (NIRE) — are set out in Chapters 4 and 5, and different rules for calculating Northern Ireland profits apply depending on a company's size and employment status.
• Special provisions in Chapters 8 to 15 explain how intangible fixed assets, R&D expenditure credits, land remediation relief, creative industry tax reliefs (film, television, video games, theatrical productions, orchestras and museums/galleries exhibitions) and patent box profits interact with the Northern Ireland regime.
• Additional chapters deal with partnerships operating through a Northern Ireland firm and define "excluded trades" and "excluded activities" whose profits cannot qualify as Northern Ireland profits, together with a power to specify the treatment of "back-office activities".