»Ê¹ÚÌåÓýapp

S940B-S953 Corporation Tax Act 2010 (CTA 2010)

»Ê¹ÚÌåÓýapp rules on transfers of trades in CTA 2010 do not apply to transfers of television programme trades between companies in common ownership.

»Ê¹ÚÌåÓýapp legislation in CTA 2010 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, the second company is treated as succeeding to the trade of the first company.

»Ê¹ÚÌåÓýapp television tax regime permits only one company to be the Television Production Company (TPC) in relation to a programme and treats the activities of that company in relation to each programme as a separate trade.

As a result, once a programme trade has commenced it is impossible for a second company to succeed to the trade in relation to the programme. »Ê¹ÚÌåÓýapp rules in CTA 2010 do not apply.

Where a TPC carries on a trade in relation to a qualifying programme and that trade ceases, it may be able to pass any losses on to:

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

See FPC30040 for details.