Corporation Tax Act 2010 section 357UO

Restriction on use of losses before completion period

Section 357UO modifies the rules restricting the use of pre-completion period losses in the separate orchestral trade where the company involved is a Northern Ireland company, requiring losses and profits to be categorised as either Northern Ireland or mainstream.

• For a Northern Ireland company, pre-completion losses in the separate orchestral trade must be split into Northern Ireland losses and mainstream losses, and treated separately.
• Where a Northern Ireland company has Northern Ireland losses alongside mainstream profits (or vice versa) in a pre-completion period, it may claim relief for those losses against the opposite category of profits of the same period.
• Relief is strictly limited: Northern Ireland losses can only be set against mainstream profits of the same period, and mainstream losses can only be set against Northern Ireland profits of the same period.
• The completion period is the accounting period in which the orchestral concert or series of concerts is completed, as defined in the Corporation Tax Act 2009.