Losses: pre-completion periods
S1216DA Corporation Tax Act 2009 (CTA 2009)
Relief limited to carry forward
The rules in Part 15A CTA 2009 restrict the normal loss relief rules prior to completion of the programme.
Where a Television Production Company (TPC) has a trading loss in any period before that in which the programme is completed, any loss that is not surrendered for payable tax credit can only be carried forward to be relieved against profits of the same trade.
Exceptionally, where a programme trade for an uncompleted programme has made a profit in an earlier year, losses cannot be carried back to 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 programme trade, not just those attributable to the relief element of Television Tax Relief and/or enhanceable expenditure.