»Ê¹ÚÌåÓýapp

CTA10/Part 22/Chapter 1

CTA10/Part 22/Chapter 1 applies to transfers of a trade between companies in common ownership. »Ê¹ÚÌåÓýapp legislation prevents the trade from being treated as permanently discontinued in the hands of the first company and a new trade starting in the hands of the second company. Instead, CTA10/Part 22/Chapter 1 treats the second company as succeeding to the trade of the first company.

»Ê¹ÚÌåÓýapp film tax regime introduced by FA06 permits only one company to be the film production company (FPC) in relation to a film, and treats the activities of that company in relation to each film as a separate trade.

Once a film production activity has commenced, it is impossible for a second company to succeed to the trade in relation to the film. CTA10/Part 22/Chapter 1 therefore does not apply.

Where an FPC carries on a trade in relation to an FTR-qualifying film and that trade ceases, it may be able to pass any losses on either:

• to another trade in relation to a qualifying film that it is carrying on at the time of the cessation, or
• to another trade in relation to a qualifying film that another group company is carrying on at the time of the cessation.

See FPC30040 for more details.