Corporation Tax Act 2010 section 357MA

Northern Ireland profits or losses and mainstream profits or losses

Section 357MA establishes how trading profits and losses are split between Northern Ireland profits or losses (taxable at the Northern Ireland rate) and mainstream profits or losses (taxable at the standard UK corporation tax rate).

• Where a trade qualifies under section 357KB(1) as a non-excluded trade, its profits and losses are treated as Northern Ireland profits or losses except to the extent they arise from an excluded activity.
• Where a trade qualifies under section 357KB(2) as an excluded trade with back-office activities, only the back-office profits (as determined under section 357MB) count as Northern Ireland profits.
• Any profits or losses that do not qualify as Northern Ireland profits or losses are treated as mainstream profits or losses, taxable at the standard UK corporation tax rate.
• Other provisions in the legislation can override these rules, either by classifying profits or losses as Northern Ireland or mainstream independently of this section.