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HMRC internal manual

Orchestra Tax Relief

Orchestra Tax Relief: losses: pre-completion periods

S1216SA Corporation Tax Act 2009 (CTA 2009)

Relief limited to carry forward

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

Where an Orchestral 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 theatrical trade), any loss that is not surrendered for Orchestra Tax Credit can only be carried forward to be relieved against profits of the same trade in a subsequent period.

Exceptionally, where a separate orchestral trade for an ongoing concert or series 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 orchestral trade, not just those attributable to Orchestra Tax Relief.

These provisions are not altered by the new loss relief provisions brought in from 1 April 2017 for pre-completion periods.