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HMRC internal manual

Museums and Galleries Exhibition Tax Relief

Museums and Galleries Exhibition Tax Relief: Taxation: Profit/loss calculation: Expenditure - Nature

Part 15E Corporation Tax Act 2009 (CTA 2009)

Where profits or losses of the separate exhibition trade of a Museums and Galleries Exhibition Production Company (MGEPC) are within the rules of Part 15E CTA 2009, the expenditure to be brought into account in calculating the profit or loss will be all the expenditure incurred on:

  • activities involved in developing, producing, running, deinstalling and closing the exhibition, and
  • activities with a view to exploiting the exhibition

The rules in Part 15E CTA 2009 determine how income and expenditure of an exhibition are brought into account as debits and credits in computing the profit of the separate exhibition trade. These rules take precedence over the intangibles regime for expenditure which is related to curating the exhibition (S808E CTA 2009).

Where income or expenditure is not related to curating the exhibition and is subject to a specific tax regime (for example, the loan relationships or intangibles regimes), the computational rules in those regimes will take priority, as they do for other trades.  Any trading debit or credit arising from those regimes will then be brought into account in addition to those for MGETR.

The normal rules determining whether particular items are allowable for tax purposes in computing the profits of a trade (see BIM42051+ of the Business Income Manual) still apply.

For more information on the loan relationships legislation in particular, see CFM30000+ of the Corporate Finance Manual.

No double deductions

Expenditure is not deductible under Part 15E CTA 2009 if it has been relieved under the reliefs available for Research and Development (R&D) expenditure (CIRD80000 of the Corporate Intangibles Research & Development Manual).  These reliefs are the SME scheme, large company scheme and the Research and Development Expenditure Credit scheme.