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HMRC internal manual

Orchestra Tax Relief

Orchestra Tax Relief: losses: introduction

S1217S-S1217SC Corporation Tax Act 2009 (CTA 2009)

Where a qualifying Orchestral Production Company (OPC) makes an Orchestra Tax Relief (OTR) claim in relation to a concert the profits or losses of the separate orchestral trade are calculated by the rules in Part 15D CTA 2009.  OTR may create or increase the losses of the trade for tax purposes.

There are restrictions on the use of losses of a separate orchestral trade of an OPC.

Losses of a separate orchestral trade that are not surrendered for an Orchestral Tax Credit are only available to:

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


For normal trades outside of OTR 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 theatrical trade within Part 15D CTA 2009 until the period in which the trade ceases.