CREC044200 - Losses: examples: terminal losses applied to new production

A video gamesÌýdevelopment company (VGDC) develops Video Game 1 and claims VGEC. The separateÌýtrade for the purposes of Part 14A CTA 2009 commences on 3 October 2024 and the VGDCÌýdraws up accounts to 31 DecemberÌýeach year.Ìý

The accounting periods to be considered areÌýtherefore:Ìý

  • 3 October to 31 December 2024Ìý

  • Year ended 31 December 2025Ìý

  • Year ended 31 December 2026Ìý

Video Game 1 is completed on 11 March 2025. The company ceases its video game trade in respect of Video Game 1 on 23ÌýOctober 2025,Ìýwhen it sells the rights to Video Game 1 outright.Ìý

On 10ÌýAprilÌý2025, the VGDC commences a new video game trade in relation to Video Game 2 which also qualifies for VGEC.Ìý

Note: the expenditure credits in this example are calculated on the assumption that UK expenditure is less than 80% of relevant global expenditure. In reality, theÌýamount of credit due will vary depending on the proportion of UK expenditure. For guidance on how to calculate the amount of expenditure credit due for an accounting period, please see Chapter 6 of this manual.Ìý

The computations for the first period show:Ìý

Period ended 31 December 2024Ìý

Video Game 1 (£)Ìý

Video Game 2 (£)Ìý

Other (£)Ìý

Income from the video gameÌý

200,000Ìý

-Ìý

-Ìý

Costs of the video gameÌý

(1,000,000)Ìý

-Ìý

-Ìý

Expenditure credit (34%)Ìý

340,000Ìý

-Ìý

-Ìý

Profit/(loss) on video gameÌý

(460,000)Ìý

-Ìý

-Ìý

Other incomeÌýâ€� non-trade loan relationshipÌý

-Ìý

-Ìý

15,000Ìý

Ìý
The computation shows a trading loss of £460,000 on Video Game 1.ÌýAs this is a pre-completion period, the loss is restricted and cannot be offset against other income. The interest income (the non-trade loan relationship income) is therefore taxable. The £460,000 loss is carriedÌýforward to the next accounting period.Ìý

In the next accounting period, the computations show:Ìý

Period ended 31 December 2025Ìý

Video Game 1 (£)Ìý

Video Game 2 (£)Ìý

Other (£)Ìý

Income from the video gameÌý

400,000Ìý

450,000Ìý

-Ìý

Costs of the video gameÌý

(300,000)Ìý

(600,000)Ìý

-Ìý

ExpenditureÌýcredit (34%)Ìý

102,000Ìý

204,000Ìý

-Ìý

Profit/(loss) on video gameÌý

202,000Ìý

54,000Ìý

-Ìý

Other incomeÌýâ€� non-trade loan relationshipÌý

-Ìý

-Ìý

5,000Ìý

Ìý
The computation shows a profit of £202,000 on Video Game 1 and a profit of £54,000 on Video Game 2.Ìý

Since Video Game 1 was completed on 11 March 2025, this is the completion period in respect of Video Game 1. It is also the cessation period of the trade, becauseÌýthe rights were sold on 23ÌýOctober 2025.Ìý

The brought forward lossÌýof £460,000 reduces the profit of Video Game 1 for the current period to nil. This leaves an unutilisedÌýloss of £258,000Ìý(£460,000 - £202,000).Ìý

As this is theÌýcompletion period, the remaining lossÌýcan be:Ìý

  • set against other profits of the same accounting period (theÌý£54,000 trading profit on Video Game 2 and theÌý£5,000 non-trade loan relationship income),Ìý

  • carried back against profits of the accounting period ended 31 December 2024 (the £15,000 non-trade loan relationship income),Ìý

  • surrendered as group relief, if available.Ìý

Any unused loss is carried forward again for set off against profits of the same trade.Ìý

TheÌýVGDCÌýuses the remaining lossÌýas follows:Ìý

-Ìý

£Ìý

Set against other profits of the same accounting periodÌý(£54,000 + £5,000)Ìý

£59,000Ìý

Carried back against profits of the previousÌýperiodÌý

£15,000Ìý

Surrendered as group reliefÌý

£20,000Ìý

Ìý

£94,000Ìý

Ìý
This is the maximumÌýamount that can be relieved. It leaves nilÌýtotal taxable profits for the VGDC in both periods.ÌýThere is a £164,000Ìý(£258,000 - £94,000)Ìýunused loss remaining.Ìý

This loss would normally beÌýcarriedÌýforward against profits of the same trade.ÌýHowever, the trade for Video Game 1 ceases in this period, so there are no future periods for the trade. The VGDC claims terminal loss relief under s1179BG, which meansÌýthe losses are transferred to the trade of Video Game 2. This trade will therefore treat the £164,000Ìýlosses as brought forward lossesÌýin the next accounting period.Ìý

The computations for the next period show:Ìý

Period ended 31 December 2026Ìý

Video Game 1Ìýâ€� CeasedÌý(£)Ìý

Video Game 2 (£)Ìý

Other (£)Ìý

Income from the video gameÌý

-Ìý

300,000Ìý

-Ìý

Costs of the video gameÌý

-Ìý

(350,000)Ìý

-Ìý

Expenditure credit (34%)Ìý

-Ìý

119,000Ìý

-Ìý

Profit/(loss)Ìýon video gameÌý

-Ìý

69,000Ìý

-Ìý

Other incomeÌýâ€� non-trade loan relationshipÌý

-Ìý

-Ìý

50,000Ìý

Ìý
The computation for this period shows a trading profit of £69,000 for Video Game 2. The losses deemedÌýto be brought forward of £164,000 are utilisedÌýagainst this profit first.Ìý

The profit isÌýreduced to nilÌýand there are £95,000ÌýofÌýlosses remaining. They cannot be set against the non-trade loan relationship income because losses transferred under s1179BG can only be used against the profits of the separate trade for Video Game 2.ÌýÌý

The unused £95,000 loss is deemedÌýto be brought forward for Video Game 2 at the beginning of the next period.Ìý

The following table shows how the losses from Video Game 1 are used in the various accounting periods:Ìý

-Ìý

Video Game 1 losses (£)Ìý

Video Game 2 losses (£)Ìý

APE 31/12/2024Ìý

Development period lossÌý

460,000Ìý

-Ìý

Losses carried forward into completion periodÌý

460,000Ìý

-Ìý

APE 31/12/2025Ìý

Losses brought forwardÌý

460,000Ìý

-Ìý

Set off against Video Game 1 profitÌý

(202,000)Ìý

-Ìý

Set off against NTLRÌý

(5,000)Ìý

-Ìý

Set off against Video Game 2 profitÌý

(54,000)Ìý

Ìý

Carried back against NTLR of previousÌýperiodÌý

(15,000)Ìý

-Ìý

Surrendered as group reliefÌý

(20,000)Ìý

-Ìý

Losses carried forward under terminal loss relief rulesÌý

164,000Ìý

-Ìý

APE 31/12/2026Ìý

Losses brought forwardÌý

-Ìý

164,000Ìý

UtilisedÌýagainst profits of Video Game 2Ìý

-Ìý

(69,000)Ìý

Losses carried forwardÌý

-Ìý

95,000Ìý