Corporation Tax Act 2010 section 357OJ

Assets representing production expenditure on films

Section 357OJ determines when an intangible asset representing film production expenditure is treated as having been created, for the purpose of deciding whether it is a pre-commencement asset under the Northern Ireland rate provisions.

  • An asset representing production expenditure on a film is treated as created when the film is completed, not when individual expenditure is incurred during production.
  • A film is considered "completed" when it is first in a form ready for copies to be made and distributed for presentation to the general public.
  • This timing rule determines whether the asset is classified as a pre-commencement asset (created before the Northern Ireland rate commencement day) or a post-commencement asset.
  • The definitions of "film", "completed", and "production expenditure" all follow those used in the film production company tax relief rules in Part 15 of Corporation Tax Act 2009.

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