Calculation: additional deduction - multi-period developments
S1217CG Corporation Tax Act 2009
Where the development of a video game covers more than one period of account, Video Games Tax Relief (VGTR) operates on a cumulative basis. This means that:
- In the first period of account the level of the Video Games Development Company’s (VGDC’s) enhanceable expenditure is determined by the amount of core expenditure incurred within that period.
- In subsequent periods of account, including the final period, the level of the enhanceable expenditure is calculated by reference to total expenditure incurred by the VGDC to date, taking account of VGTR received in earlier periods.
Example: development continues for several periods
A VGDC makes a video game with total core expenditure of £1m, of which 75% is incurred on video game development in the EEA, and 25% incurred on video game development outside the EEA. The video game is produced over three years.
The VGDC is eligible for VGTR and the rate of enhancement is 100% (VGDC55030).
Over the three accounting periods, the profile of core expenditure is:
|EEA (£k)||Non- EEA (£k)||Total Cumulative (£k)|
In the first period of account, because all the core expenditure is EEA core expenditure, VGTR is calculated on the basis of 80% of the total core expenditure, or £280k (= 80% x £350k). The additional deduction is therefore £280k.
At the end of the second period of account, the total core expenditure to date is £800k, of which £700k is EEA core expenditure. Because EEA core expenditure is greater than 80% of total core expenditure (80% x £800k = £640k), VGTR is provided on the basis of 80% of the total core expenditure incurred to date. The additional deduction is £640k.
However, £280k of VGTR has been claimed in the previous accounting period, leaving £360k (= £640k less £280k) to be claimed in the second period.
At the end of the third period of account, total core expenditure is £1m, of which £750k is EEA core expenditure. Because EEA core expenditure is less than 80% of the total core expenditure, the VGDC is eligible to VGTR on the full £750k. The additional deduction is therefore £750k.
Because an additional deduction of £640k has been claimed to date, this leaves £110k (= £750k less £640k) to be claimed in the third accounting period.
The cumulative effect at the end of the three periods of account is that VGTR is provided on the 75% of core expenditure that was also EEA expenditure.
|Period 1||Period 2||Period 3|
|EEA Core Expenditure (cumulative)||£350k||£700k||£750k|
|Non-EEA Core Expenditure (cumulative)||£nil||£100k||£250k|
|Total Core Expenditure (cumulative)||£350k||£800k||£1m|
|EEA core expenditure as percentage of total||100%||87.5%||75%|
|Enhanceable expenditure to end of period (lesser of EEA core expenditure or 80% of total)||£280k|
|(80% of total )||£640k|
|(80% of total)||£750k|
|Additional deduction to end of period||£280k|
|Less additional deduction claimed for earlier period(s)||-||(£280k)||(£640k)|
|Additional deduction due for the period||£280k||£360k||£110k|