Corporation Tax Act 2010 section 357UQ

Terminal losses

Section 357UQ ensures that when a museum or gallery exhibition company has a terminal loss that qualifies as a Northern Ireland loss, any election or claim to transfer that loss is treated consistently within the Northern Ireland corporation tax regime.

• When a museum or gallery exhibition company ceases trading and has a terminal loss that is a Northern Ireland loss, special rules apply to how that loss can be used.
• If the company elects to treat all or part of the terminal loss as a loss brought forward of a different trade it carries on, and the terminal loss is a Northern Ireland loss, it must be treated as a Northern Ireland loss brought forward — not simply a general loss brought forward.
• If the company claims to transfer all or part of the terminal loss so that it is treated as a loss brought forward by a different company, and the terminal loss is a Northern Ireland loss, it must again be treated as a Northern Ireland loss brought forward in the hands of that other company.
• The effect of these rules is to preserve the Northern Ireland character of the terminal loss, ensuring it remains within the Northern Ireland tax regime and is relieved at the appropriate Northern Ireland rate of corporation tax.