188ÌåÓý

Section 1179CA Corporation Tax Act 2009Ìý

Step 1

Find the amount of relevant global expenditure incurred on the production up to the end of the accounting period for which the company is making a claim. This includes any expenditure incurred on the same production in previousÌýaccounting periods.Ìý

Relevant global expenditure isÌýcoreÌýexpenditure that must be brought into account as part of the separate production trade (CREC031000). ItÌýalso must not be excluded expenditure.ÌýÌý

Core expenditure is expenditure incurred on:Ìý

Excluded expenditure is expenditure that qualifies for relief under one of the Research and Development (R&D)Ìýschemes, or expenditure that representsÌýconnected party profit if the arm’s length exception does not apply â€� see CREC052000.Ìý

See CREC051000 for detailed guidance on relevant global expenditure.

Relevant global expenditure includes any relevant visual effects expenditure (CREC061420) incurred on a production, even if the company is claiming additional credit for visual effects costs.

Step 2Ìý

Deduct any expenditure incurred on the production that is not UK expenditure (CREC054000). UK expenditure is expenditure on goods and services that are used or consumed in the UK, so at this step companies should deduct any expenditure thatÌýis notÌýused or consumed in the UK.ÌýÌý

The result is the amount of UK expenditure to date.

Independent films (CREC021100)

For independent films (known in legislation as certified low-budget films), relevant global expenditure at step 1 is capped at £15 million. If a company has incurred more than £15 million relevant global expenditure on an independent film at the end of an accounting period, it can still make a claim, but it can only include a maximum of £15 million relevant global expenditure at step 1 of its expenditure credit calculation. Please see CREC063300 for an example.

For step 2, UK expenditure counts towards the £15 million cap before non-UK expenditure, even if UK expenditure is incurred after non-UK expenditure. This maximises the relief a company can receive within the cap.

Example

Company A incurs £12 million relevant global expenditure on an independent film in its first accounting period. Of that £12 million, £8 million is UK expenditure and £4 million is non-UK expenditure.

In the next period, Company A incurs a further £5 million relevant global expenditure, all of which is UK expenditure. The total relevant global expenditure on the film is now £17 million, and UK expenditure is £13 million. Only £15 million of the £17 million total can be included at step 1 of the credit calculation.

At step 2, Company A assumes that all £13 million UK expenditure is within the £15 million from step 1, even though the £5 million of UK expenditure incurred in the second accounting period was incurred later than the non-UK expenditure.

Therefore, UK expenditure to date is:

£15 million relevant global expenditure (step 1)

Minus £2 million non-UK expenditure

Equals £13 million.