Corporation Tax Act 2010 section 357OF

Northern Ireland element: general rule

Section 357OF sets out the general rule for calculating how much of a realisation credit or debit on an intangible fixed asset is treated as the Northern Ireland element for the purposes of the Northern Ireland corporation tax rate.

• Where an intangible asset has been written down for tax purposes, a formula is used to calculate the Northern Ireland element based on the proportion of cumulative write-down debits that were Northern Ireland debits
• Where an asset has not been written down for tax purposes, or does not appear on the balance sheet, the Northern Ireland element is instead determined on a just and reasonable basis by reference to how far the asset was held for the purposes of the relevant Northern Ireland trade
• The general rule does not apply to a realisation credit where roll-over relief under section 357OG is in point
• The relevant Northern Ireland trade means the company's qualifying trade carried on during periods when it was a Northern Ireland company, excluding any excluded activities