Corporation Tax Act 2010 section 357WBA

Northern Ireland workforce partnership conditions

Section 357WBA sets out the two workforce conditions that a partnership must satisfy in order to qualify as a Northern Ireland workforce partnership for the purposes of the Northern Ireland corporation tax rate.

• At least 75% of the firm's UK workforce working time during the period must be spent in Northern Ireland, and at least 75% of the firm's UK workforce expenses must be attributable to time spent in Northern Ireland.
• The firm's workforce includes employees, externally provided workers and individual partners in the firm.
• Workforce expenses are the total staff-cost deductions (such as wages, salaries, commissions and bonuses, but not expenses or travel and subsistence) made in calculating the firm's trading profits, apportioned on a daily basis where the relevant period does not coincide with an accounting period.
• HMRC may make regulations specifying which types of deduction do or do not count as workforce expenses for these purposes.