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HMRC internal manual

Museums and Galleries Exhibition Tax Relief

Museums and Galleries Exhibition Tax Relief; losses; introduction

S1218ZD-S1218ZDC Corporation Tax Act 2009 (CTA 2009)

Where a qualifying Museums and Galleries Exhibition Production Company (MGEPC) makes an Museums and Galleries Exhibition Tax Relief (MGETR) claim in relation to An exhibition the profits or losses of the separate exhibition trade are calculated by the rules in Part 15E CTA 2009.  MGETR may create or increase the losses of the trade for tax purposes.

There are restrictions on the use of losses of a separate exhibition trade of a MGEPC.

Losses of a separate exhibition trade that are not surrendered for a tax credit are only available to:

  • carry forward for relief against future profits of the same exhibition trade
  • use against other profits of the company or surrender through group relief once the exhibition has been completed, and
  • transfer or surrender under specific MGETR rules for terminal losses.

 

For normal trades outside of MGETR or similar regimes, losses may be set off in a number of ways including against other income or surrendering to other companies in a group.  This is not possible for a separate exhibition trade within Part 15E CTA 2009 until the period in which the trade ceases.

The alteration of the loss relief rules introduced from 1 April 2017 do not alter the treatment of losses prior to an accounting period which is the completion period.

In the completion and subsequent accounting periods different rules apply to attributable and non-attributable losses. The rules for non-attributable losses are covered in the XXX manual. Attributable losses are dealt with later in this chapter.