Section 357JC — Corporation Tax Act 2010: Restriction on deductions

Restriction on deductions 357JC 1 Subsection (2) applies where—

a relief is given under section 37 for a Northern Ireland loss (“the loss”),

b the profits against which the relief is given include profits that are not Northern Ireland profits, and c at any time during the accounting period for which the relief is given (“the profit period”) the Northern Ireland rate is lower than the main rate.

2 The reference in section 37(4) to “the amount of the loss” is to the restricted deduction for the loss, as determined under section 357JJ (restricted deduction where Northern Ireland rate lower than main rate).

3 Subsection (4) applies where—

a relief is given under section 45A, 45B or 45F for an amount of a Northern Ireland loss (“the loss”),

b the profits against which the relief is given include profits that are not Northern Ireland profits, and c at any time during the accounting period for which the relief is given (“the profit period”), the Northern Ireland rate is lower than the main rate.

4 The reference in section 45A(6), 45B(4) or (as the case may be) 45F(5) to “the unrelieved amount” is to so much of that amount as is equal to the restricted deduction for the loss, as determined under section 357JJ.