Corporation Tax Act 2010 section 357NE

Provision of goods or services for NIRE

Section 357NE explains how to treat goods or services that a company provides to its own Northern Ireland Regional Establishment (NIRE), distinguishing between items the company normally sells to outside parties and those it does not.

• Where a company provides goods or services to its own NIRE, specific rules determine how the transaction is treated for tax purposes.
• If the goods or services are of a type the company ordinarily sells to independent third parties at arm's length, the transaction is treated under the separate enterprise principle — meaning it is priced as if the NIRE were a separate, independent business.
• If the goods or services are not of a type the company normally supplies to outside parties, the cost is simply treated as an expense incurred by the company for the purposes of its NIRE, following the rules on allowable deductions in section 357NF.
• The distinction matters because it determines whether a market-value pricing approach applies or whether the company simply claims the cost as a deductible expense of the NIRE.