Corporation Tax Act 2010 section 357KB

Qualifying trade

Section 357KB defines what constitutes a "qualifying trade" for the purposes of the Northern Ireland corporation tax rate, including a special election mechanism that allows certain otherwise excluded trades to qualify where they include back-office activities.

  • A qualifying trade is one carried on by a company (not in partnership) that is within the charge to corporation tax and is not an excluded trade.
  • A company may elect to treat certain excluded trades — specifically lending and investment, investment management, or re-insurance — as qualifying trades, but only if those trades include back-office activities.
  • The election must be notified to HMRC, must specify the first accounting period it applies to, and must be made within 12 months of the end of that accounting period.
  • Once validly made, the election takes effect from the specified accounting period onwards and is irrevocable.

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