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HMRC internal manual

Orchestra Tax Relief

Orchestra Tax Relief: taxation: profit/loss calculation: matching income to expenditure in different periods of account

S1217QB, S1217QG Corporation Tax Act 2009 (CTA 2009)

Part 15D CTA 2009 sets out how the profits and losses of a separate orchestral trade of Orchestra Production Companies (OPCs) are calculated for tax purposes.

Calculation of profit or loss:  first period of account after trading begins

In the first period of account following the commencement of the separate orchestral trade there are no costs reflected in work done that are attributable to a preceding accounting period because any pre-trading expenditure is treated as work of the first accounting period

The expenditure to be taken into account as a debit in calculating the taxable profit/loss is the expenditure of the first period that is reflected in the state of completion of the concert or series The income to be taken into account as a credit in calculating the taxable profits of the first accounting period is the income that is treated as earned at the end of the accounting period using the formula at OTR30250.

If a separate orchestral trade commences and ceases within a single accounting period, this will be the normal method for calculating the profit or loss attributable to the theatrical production.

Calculation of profit or loss: subsequent periods of account

In subsequent periods of account the profit for the period is calculated by comparing the further work done measured by the additional expenditure and the increase, or decrease, in the income treated as earned by the production.

The expenditure to be taken into account as a debit in calculating the taxable profit is the expenditure to date, reflected in the state of completion of the concert or series, less the expenditure to date at the end of the previous accounting period.  This gives the expenditure of the accounting period that is reflected in the state of completion of the concert or series.

The income to be taken into account as a credit in calculating the taxable profits is the income that is treated as earned at the end of the accounting period using the formula at OTR30250 less the income treated as earned at the end of the previous accounting period.  This gives the increase or decrease in the income treated as earned in the accounting period.