Taxation: separate trade - introduction
Part 15A Ch 2 S1216B-S1216BF Corporation Tax Act 2009 (CTA 2009)
Where a company is a Television Production Company (TPC) (TPC10110) for the purposes of Part 15A CTA 2009, the production of each television programme is treated as a separate trade.
A programme includes all episodes and series produced within an individual contract for that programme. There can be a number of parts of a self-contained work and these are treated as a single programme (TPC10100). See TPC20130 for further detail of how this applies.
For each programme, the profits and losses must be calculated separately. Also, the rules applying to a trade should be applied to each programme.
In producing their statutory accounts, TPCs may account for their costs and income in a number of ways. This will vary according to their operating model and how they think best represents a true and fair view of the business.
The rules in Part 15A CTA 2009 therefore set out a consistent approach to calculating taxable profits of TPCs. This applies to the separate programme trade whether Television Tax Relief (TTR) is claimed or not.
This approach is important when considering relief for losses.
There are special provisions which restrict the ways in which losses arising from a television production trade can be used and this will vary depending on whether or not the programme has been completed and the trade has ceased (TPC20110).
The Part 15A CTA 2009 basis applies a revenue treatment to income and to certain types of expenditure that would otherwise be treated as capital expenditure (TPC20200).