CREC038000 - Taxation: matching income to expenditure

Section 1179BB Corporation Tax Act (CTA)Ìý2009Ìý

Chapter 2 Part 14A CTA 2009 sets out how the profits and losses of a separate productionÌýtrade are calculated for tax purposes.Ìý

The method is modelled on the way in which profits are recognisedÌýin construction contracts (or long-term contracts). This means recognisingÌýexpected income in line with the state of completion of the production, as measured by the proportion of total costs to date that has been expended.Ìý

It operatesÌýby:Ìý

  • calculating what proportion of the production's estimated total costs have been incurred (and are reflected in work done) within each accounting period, andÌý

  • allocatingÌýthe pro»å³Ü³¦³Ù¾±´Ç²Ô’s estimated total income to each period in similar proportions.Ìý

This method will adjust for both changes to the estimated total income from the programme, (for example, sale of further rights) and to changes in the estimated total cost (due, for example, to a change of plans during shootingÌýor testing).Ìý

In the calculation:Ìý

  • the estimated total cost of the production will be the expected cost of making the production, plus any expected exploitation costs (CREC037100), andÌý

  • theÌýestimated total income will be all the expected income from the productionÌý(CREC036100).Ìý


Estimated costs and income
Ìý

A production companyÌýmay need to estimate both total expected costs and total expected income to be able to operateÌýthe formula to determineÌýtaxable profits or losses.Ìý

Where actual income and costs are known, this estimate is not necessary. For example, if a productionÌýhas been sold and no rights to further income from that production retained, then the income is the proceeds of the sale.

Estimated total costsÌý

The estimated total cost will generally beÌýthe total estimated allowable costs shown by the most recent and reliable estimate in the production budget, plus a realistic estimated cost to the productionÌýcompany of exploiting any rights in the production that it retains.Ìý

Budgets of this sort are generally maintainedÌýby companies both as a management tool and because their existence is generally aÌýcondition imposed by the completion guarantor and the financiers or commissioning broadcaster.

Estimated total incomeÌý

The estimated total income from the productionÌýis the total income, received or expected, from the productionÌýover its life.Ìý

The estimate of income should include income from all sources (CREC036100),Ìýbut it should only include income that the productionÌýcompany is in a position to realistically expect and quantify.ÌýThis does not include hypothetical or potential income merely because a prediction of that income has been made such as by a sales agent. The realistic expectation of income is closer to that included in the statutory accounts.Ìý

So,Ìýthe estimated income should broadly include that income which the company would be confident enough to include in its Profit & Loss account were the production to be treated as being on revenueÌýaccount.Ìý

Whether any particular contract or agreement gives the company rights such that income should be recognisedÌýunder these rules will be a question of fact. See below for further detail of how estimates are to be made.

Calculating total income earned at the end of an accounting periodÌý

At the end of any accounting period,Ìýthe amount of income treated as earned is calculatedÌýusing the formulaÌý

(C/T)Ìýx IÌý

where:Ìý

  • C = total to date of costs incurred on theÌýproductionÌýand reflected in work doneÌý

  • T = estimated total costs of the productionÌý

  • I = estimated total income of the productionÌý

See CREC039000 for examples of these calculations.Ìý