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HMRC internal manual

Museums and Galleries Exhibition Tax Relief

Museums and Galleries Exhibition Tax Relief: losses; pre-completion periods

S1218ZDA Corporation Tax Act 2009 (CTA 2009)

Relief limited to carry forward

The rules in Part 15E CTA 2009 restrict the normal loss relief rules prior to completion of the concert.

Where a Museums and Galleries Exhibition Production Company has a trading loss in any period before the completion period (the accounting period in which the company ceases to carry on the separate exhibition trade), any loss that is not surrendered for Museums and Galleries Exhibition Tax Credit can only be carried forward to be relieved against profits of the same trade in a subsequent period.

Exceptionally, where a separate exhibition trade for an ongoing exhibition has made a profit in an earlier year, losses cannot be offset against the profit.  This may occur where income, such as a grant, has created a profit.

This restriction applies to all losses of the separate exhibition trade, not just those attributable to Museums and Galleries Exhibition Tax Relief.