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HMRC internal manual

Business Income Manual

HM Revenue & Customs
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Trade losses - restriction of relief: non-active traders - film-related expenditure

S74D Income Tax Act 2007

The £25,000 annual limit on losses for which sideways loss relief can be claimed by non-active traders does not apply to losses derived from qualifying film expenditure.

Qualifying film expenditure

Qualifying film expenditure is that deducted under the old film relief provisions described in BIM56500.

The extent to which the expenditure was qualifying film expenditure was determined on a just and reasonable basis.

Film GAAP schemes

The annual limit applies to losses derived from other (non-qualifying) film-related expenditure. In particular it does apply to losses derived from deductions made for revenue expenditure in accounts of film partnerships prepared in accordance with generally accepted accounting practice (GAAP schemes).