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HMRC internal manual

Theatre Tax Relief

Losses: introduction

S1217M-S1217MC Corporation Tax Act 2009 (CTA 2009)

Where a qualifying Theatrical Production Company (TPC) makes a Theatre Tax Relief (TTR) claim in relation to a theatrical production the profits or losses of the separate theatrical trade are calculated by the rules in Part 15C CTA 2009.  TTR may create or increase the losses of the trade for tax purposes.

There are restrictions on the use of losses of a separate theatrical trade of a TPC.

Losses of a separate theatrical trade that are not surrendered for a Theatre Tax Credit are only available to:

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

For normal trades outside of TTR 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 15C CTA 2009 until the period in which the trade ceases.