TPC10010 - Overview and general definitions: introduction
Part 15A Corporation Tax Act 2009
Ìý
Finance Act 2013Ìý(Now incorporated into CTA 2009 Part 15A) introduced a new regime for the taxation of Television Production Companies (TPCs) and a new relief for the television industry, Television Tax Relief (TTR).
»Ê¹ÚÌåÓýapp legislation on TPCs provides specific rules for relief on television programmes including high-end television productions and animations. »Ê¹ÚÌåÓýapp rules state how all television production trades should be taxed, as well as laying down the conditions for TTR.
Tax treatment
For tax purposes only, the legislation:
- deems that the production of each programme is a separate trade with a start and end date separate to that of the company,
- describes what income and expenditure is eligible for additional tax relief and circumstances where there are exceptions to the normal rules for income and expenditure, and
- restricts the use of losses associated with that trade in certain circumstances.
This applies for all television production trades.
TTR applies to expenditure on relevant programmes by a TPC (TPC10110). Animations are relevant programmes. »Ê¹ÚÌåÓýappre are some specific rules related to animations.
If there is no TPC for a programme, then the rules do not apply. This might be because:
- no company meets the required criteria, or
- the company has elected to be treated as not meeting the criteria.
Television Tax Relief (TTR)
TTR applies to TPCs engaged in the making of:
- a British programme (TPC40030),
- that is intended for broadcast (TPC40020), and
- at least 25% of core expenditure (TPC50010) is incurred on goods or services used or consumed in the United Kingdom. ÌýFrom 1 April 2015 this reduces to 10% for programmes which had not completed principal photography by that dateÌý(TPC50050).
Those TPCs that are entitled to TTR can claim:
- an additional deduction in computing their taxable profits (TPC55010), and
- where that additional deduction results in a loss, to surrender losses for a payable tax credit (TPC55100).
Both the additional deduction and the payable credit are calculated on the basis of UK core expenditure up to a maximum of 80% of the total core expenditure by the TPC. Core expenditure is expenditure on pre-production, principal photography and post-production.
Commencement: TTR
TTR is available for expenditure that is used or consumed on or after 1 April 2013.