Corporation Tax Act 2010 section 357NF

Allowable deductions

Section 357NF sets out the rules for deducting allowable expenses when calculating the profits attributable to a company's Northern Ireland Regional Establishment (NIRE).

• A deduction is permitted for any allowable expenses incurred for the purposes of the NIRE when calculating its attributable profits.
• Qualifying expenses include executive and general administrative costs, whether incurred in Northern Ireland or elsewhere, and regardless of whether they are paid by or reimbursed by the NIRE.
• The amount deductible is the actual cost to the company, not any notional or estimated figure.
• Allowable expenses are those for which a corporation tax deduction would normally be available — and for non-UK-resident companies, the test is whether a deduction would be available if the company were UK-resident.