Corporation Tax Act 2010 section 357WB

Meaning of "qualifying partnership trade"

Section 357WB defines what counts as a "qualifying partnership trade" for the purposes of the Northern Ireland corporation tax rate, including how certain excluded financial trades can be brought within the definition through an irrevocable election.

  • A qualifying partnership trade is any trade carried on by a firm that is not an excluded trade.
  • Certain excluded financial trades — lending and investment, investment management, and reinsurance — can qualify if the firm elects and the trade includes back-office activities.
  • The election must be notified to HMRC within 12 months of the end of the first accounting period to which it relates, and once made it is irrevocable.
  • The election takes effect from the specified accounting period onwards and cannot be reversed.

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