Television tax reliefs ― key provisions

By Tolley
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The following Corporation Tax guidance note by Tolley provides comprehensive and up to date tax information covering:

  • Television tax reliefs ― key provisions
  • Overview
  • Eligible programmes
  • Eligible companies
  • The UK expenditure requirement
  • Calculating the additional deduction
  • Losses
  • Straddling periods
  • Provisional entitlement to relief
  • The cultural tests
  • Interaction with other reliefs
  • Anti-avoidance

Overview
Taxation of television production companies

Television production companies are not taxed in the same way as other trading companies. The activities relating to the production of each television programme are treated as separate from those relating to any other television programme or any other activities being carried on by the television production company. The way in which the profits and losses of each separate programme trade are calculated is set out in the Television tax reliefs ― the separate programme trade guidance note.

CTA 2009, s 1216B; TPC20010–TPC20130; APC20010–APC20130
The three television tax reliefs (TTRs)

This guidance note sets out the provisions governing the additional tax reliefs available for television production companies. These were introduced by FA 2013 and are included in CTA 2009, ss 1216A–1216EC (Pt 15A). The rules, as initially introduced, provide relief for qualifying expenditure incurred on high-end television productions and animations. They were extended by FA 2015, s 30 to include relief for qualifying expenditure incurred on the production of children’s television programmes.

The relief available for all three categories of television production (high-end TV, animations and children’s programmes) is not separated by type in the legislation, but instead is referred to collectively as ‘television tax relief’. As such, the majority of the rules apply in much the same way to the different types of production, although there are some subtle differences in the conditions applying to animations and children’s programmes which are covered below.

The reliefs for high-end television programmes and animations are available for accounting periods commencing on or after 1 April 2013, whilst the relief for children’s programmes is only available for accounting periods commencing on or after 1 April 2015. The legislation sets out provisions dealing with accounting periods that straddle these dates ― see Straddling periods below for further guidance.

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