Corporation Tax Act 2010 section 357JB

Availability of relief

Section 357JB sets out how trade loss relief interacts with the Northern Ireland corporation tax regime, ensuring that Northern Ireland losses and mainstream losses are treated separately and matched against the appropriate type of profits.

• Where a company has Northern Ireland losses and/or mainstream losses from a trade, the normal trade loss relief provisions apply to each type of loss independently.
• If both types of loss arise in the same accounting period, the company may claim relief for one or both, and in any order it chooses.
• A Northern Ireland loss must be set off first, as far as possible, against Northern Ireland profits before it can reduce mainstream profits.
• A mainstream loss must be set off first, as far as possible, against mainstream (non-Northern Ireland) profits before it can reduce Northern Ireland profits.