»Ê¹ÚÌåÓýapp

S940B � S953 Corporation Tax Act 2010 (CTA 2010)

»Ê¹ÚÌåÓýapp rules on transfers of trades in CTA 2010 do not apply to transfers of separate orchestral trades between companies in common ownership.

»Ê¹ÚÌåÓýapp legislation in CTA 2010 prevents the separate orchestral trade from being treated as permanently discontinued in the hands of the first company and a new orchestral trade starting in the hands of the second company. Instead, the second company is treated as succeeding to the orchestral trade of the first company.

»Ê¹ÚÌåÓýapp orchestra tax regime permits only one company to be the Orchestral Production Company (OPC) in relation to a concert or series of concerts and treats the activities of that company in relation to each concert or series as a separate theatrical trade.

As a result, once a separate orchestral trade has commenced it is impossible for a second company to succeed to the trade in relation to the concert or series. »Ê¹ÚÌåÓýapp rules in CTA 2010 do not apply.

Where an OPC carries on a separate orchestral trade in relation to a qualifying concert or series and that trade ceases, it may be able to pass any losses on to:

• another separate orchestral trade in relation to a qualifying production that it is carrying on at the time of the cessation, or
• to another separate orchestral trade in relation to a qualifying concert that another group company is carrying on at the time of the cessation.

See OTR40050 for details.