Corporation Tax Act 2010 section 357WC

Northern Ireland profits etc. of firm determined under Chapter 6

Section 357WC explains how a corporate partner that is an SME has its share of a Northern Ireland firm's trading profits or losses classified as either Northern Ireland or mainstream profits or losses.

  • The section applies where a firm qualifies as a Northern Ireland firm under the SME (Northern Ireland employer) partnership condition, and one of its partners is a company that is both within the charge to corporation tax on the firm's trade and is itself an SME.
  • The corporate partner's accounting period must either coincide with or overlap the firm's accounting period for the rules to apply.
  • The normal SME rules for determining Northern Ireland profits or losses (in section 357MA) are used to classify the corporate partner's share of the firm's trading profits or losses, but only for the purpose of allocating that share to the relevant accounting period.
  • Additional rules in Chapters 8 and 15 of Part 8B, the Capital Allowances Act 2001, and section 357WH provide further detail on classification and allocation of Northern Ireland and mainstream profits or losses.

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