Corporation Tax Act 2010 section 357RF

Restriction on use of losses while film is in production

Section 357RF restricts how Northern Ireland film production companies can use their losses during the period before a film is completed, distinguishing between Northern Ireland losses and mainstream losses.

• While a film is still in production, the normal rules restricting the use of film trade losses apply, but with additional provisions for Northern Ireland companies
• Losses arising in the separate film trade during a pre-completion period are split into Northern Ireland losses and mainstream losses
• A qualifying Northern Ireland company may claim relief for pre-completion losses, but only by setting Northern Ireland losses against mainstream profits of the same period, or mainstream losses against Northern Ireland profits of the same period
• The definition of a pre-completion period follows the same meaning as used in the general film production loss rules in CTA 2009