Corporation Tax Act 2010 section 357UG

Use of losses in the completion period

Section 357UG modifies how losses arising in a separate theatrical trade during the completion period are treated when the production company is a Northern Ireland company, requiring such losses to be split into Northern Ireland losses and mainstream losses.

• When a Northern Ireland company has losses in its separate theatrical trade, those losses must be identified as either Northern Ireland losses or mainstream losses of the trade for that period.
• This split between Northern Ireland losses and mainstream losses applies both to losses brought forward from earlier periods and to losses arising in the completion period itself.
• The requirement to distinguish between the two categories of loss carries through to all the related loss relief provisions, ensuring consistent treatment throughout.
• Where the loss relief rules refer to an additional deduction for theatrical productions, Northern Ireland losses are treated as also including any Northern Ireland supplementary deduction available under the Northern Ireland provisions.