Corporation Tax Act 2010 section 357XB

Lending and investment

Section 357XB defines when a trade is an "excluded trade" because it involves lending or regulated financial activities, and therefore falls outside the Northern Ireland corporation tax regime.

  • A trade that consists of or includes a lending activity or a relevant regulated financial activity is an "excluded trade" and cannot benefit from the Northern Ireland rate of corporation tax.
  • Lending activities cover a broad range of financial services including money lending, finance leasing, payment services, guarantees, money transmission, and alternative finance arrangements.
  • Relevant regulated activities include accepting deposits, dealing in investments (as principal or agent), arranging investment deals, safeguarding investments, and entering into regulated mortgage contracts.
  • Insurance companies, as defined by section 65 of the Finance Act 2012, are specifically exempted from being treated as excluded trades even if they carry on lending or regulated activities.

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