Corporation Tax Act 2010 section 357UP

Use of losses in the completion period

Section 357UP modifies how losses in a separate orchestral trade are treated during the completion period when the company involved is a Northern Ireland company, distinguishing between Northern Ireland losses and mainstream losses.

• When a Northern Ireland company makes a loss in its separate orchestral trade, that loss must be split into Northern Ireland losses and mainstream losses, and the rules for using losses in the completion period apply separately to each category.
• This split applies both to losses brought forward from earlier periods and to losses arising in the completion period itself.
• All references to losses throughout the completion period loss rules must be read as referring to either Northern Ireland losses or mainstream losses of the trade, as appropriate.
• Where Northern Ireland losses are concerned, the reference to an additional deduction available under the orchestral concert tax relief rules is extended to include any Northern Ireland supplementary deduction available under the Northern Ireland rate provisions.