Corporation Tax Act 2010 section 357RE

Artificially inflated claims for additional deduction

Section 357RE extends the anti-avoidance rules on artificially inflated claims for additional deductions so that they also apply to Northern Ireland supplementary deductions.

• Existing anti-avoidance rules in the Corporation Tax Act 2009 prevent companies from artificially inflating claims for additional deductions or film tax credits.
• Section 357RE ensures that these same anti-avoidance rules apply equally to Northern Ireland supplementary deductions.
• This is achieved by treating references to an "additional deduction" in the relevant provisions as including a Northern Ireland supplementary deduction.
• The effect is that any arrangement designed to artificially inflate a Northern Ireland supplementary deduction will be caught and adjusted in the same way as an inflated additional deduction claim.