Corporation Tax Act 2010 section 357UW

Restriction on use of losses before completion period

Section 357UW modifies the rules restricting the use of pre-completion period losses in a separate exhibition trade, where the company carrying on that trade is a Northern Ireland company, by splitting those losses into Northern Ireland losses and mainstream losses and limiting how each category of loss may be relieved.

• For Northern Ireland companies, pre-completion losses in the separate exhibition trade are split into Northern Ireland losses and mainstream losses of the trade.
• Where a Northern Ireland company has Northern Ireland losses alongside mainstream profits (or mainstream losses alongside Northern Ireland profits) in a pre-completion period, it may claim trade loss relief against total profits under section 37.
• Relief on such a claim is restricted: 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" takes its meaning from the museums and galleries exhibition tax relief provisions in section 1218ZDA of CTA 2009.