TTR30100 - Losses: »Ê¹ÚÌåÓýappatrical Production Companies: transfer of trade

S940B � S953 Corporation Tax Act 2010 (CTA 2010)

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

»Ê¹ÚÌåÓýapp legislation in CTA 2010 prevents the separate theatrical trade from being treated as permanently discontinued in the hands of the first company and a new theatrical trade starting in the hands of the second company. Instead, the second company is treated as succeeding to the theatrical trade of the first company.

»Ê¹ÚÌåÓýapp theatre tax regime permits only one company to be the »Ê¹ÚÌåÓýappatrical Production Company (TPC) in relation to a production and treats the activities of that company in relation to each production as a separate theatrical trade.

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

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

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

See TTR30050 for details.