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HMRC internal manual

Theatre Tax Relief

From
HM Revenue & Customs
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Qualifying productions: minimum EEA expenditure

S1217GB Corporation Tax Act 2009

To be a qualifying production for Theatre Tax Relief (TTR) purposes at least 25% of the core expenditure (TPC50010) on the theatrical production incurred by the Theatrical Production Company (TPC) must be European Economic Area (EEA) expenditure.

Pre-completion periods

Whether a theatrical production meets the 25% EEA expenditure condition cannot be determined until after the end of the completion period (the accounting period in which the company ceases to carry on the separate theatrical trade in respect of the production).

But tax returns for any earlier periods (pre-completion periods) can include claims to TTR based on an expectation that the condition will be met if they include a statement of planned core expenditure that is EEA expenditure and this indicates that on completion of the theatrical production the EEA expenditure condition will be met.

Claims for pre-completion periods will be revisited, and TTR claims appropriately revised if it turns out the final amount of core expenditure that is EEA expenditure is less than 25% but claims have been made as if the condition would be met.

Final statement of the core expenditure on the theatrical production that is EEA expenditure

The tax return for the final accounting period must:

  • indicate that the theatrical production has been completed or abandoned, and
  • include a final statement of the core expenditure on the theatrical production that is EEA expenditure.

The final statement should include all core expenditure on the production by the TPC.  It should take account, as far as it is possible to estimate such amounts with reasonable certainty, of the amount of any deferred payments of core expenditure that is EEA expenditure that can be expected to be paid out in the future.