FPC30010 - Film Production Companies: Losses: Introduction
CTA2009/S1208, S1209 and S1210; CTA2010/S37, S45, S45B and Part 5
The profits or losses of a film production activity carried on by a film production company (FPC) and calculated by following the rules in CTA09/ Part 15 Chapter 2 are profits or losses of a separate trade. Film Tax Relief (FTR) - CTA09/Part15 Chapter 3 - can create or augment a loss of a film production activity.
Losses of a trade are normally available:
- to carry forward against profits of the same trade (subject to the loss restriction rules that apply from 1 April 2017 at CTA10/Part 7ZA), set sideways against other profits of the same company or carry back against profits of the same company; and
- for surrender as group relief.
This normal entitlement to relief for losses of a trade is modified for losses of a trade of film production carried on by an FPC. The modifications:
- restrict the use of losses for periods preceding that in which the film is completed
- deem losses brought forward to the period in which the film is completed or later period (to the extent that they are not attributable to FTR) to be losses of the period to which they are brought forward for the purposes of CTA10/S37 and Part 5, and
- provide for a more generous relief for terminal losses.
Guidance on the loss relief rules applying to FPCs’ film production activities
- FPC30020 - Film losses: Pre-completion periods
- FPC30030 - Film losses: Completion and later periods
- FPC30040 - Film losses: Terminal Losses