Finance Act 2024

Opting into new regime during transitional period

18 (1) If a company makes an election under section 1179B(1) of CTA 2009 in its company tax return for an accounting period beginning before 1 January 2024—

(a) Part 14A of CTA 2009 applies further to that election only in respect of the portion of the accounting period that falls on or after that date, and

(b) the relevant existing regime applies in respect of the portion of the accounting period that falls before that date.

(2) If a company makes an election under section 1179B(1) of CTA 2009 in its company tax return for an accounting period beginning on or after 1 January 2024, the relevant existing regime does not apply in relation to that accounting period or any subsequent accounting period, subject to sub-paragraphs (3) and (4).

(3) If a company makes an election under section 1179B(1) of CTA 2009 in its company tax return for an accounting period beginning on or before but ending after the relevant closure date, it may further elect in the return for sub-paragraph (4) to apply.

(4) If it does so—

(a) Part 14A of CTA 2009 applies further to the election under section 1179B(1) of CTA 2009 only in respect of the portion of the accounting period that falls after the relevant closure date, and

(b) the relevant existing regime applies in respect of the portion of the accounting period that falls on or before that date.

(5) Where, by virtue of this paragraph, different Parts of CTA 2009 apply in respect of different portions of an accounting period, the portions are to be treated as separate accounting periods for the purposes of—

(a) those Parts, and

(b) paragraphs 19 to 24 (but not for other corporation tax purposes).

(6) For the purposes of this paragraph—

(a) the “relevant existing regime” means—

(i) Part 15 of CTA 2009, if the election under section 1179B(1) of that Act relates to a film;

(ii) Part 15A of CTA 2009, if the election under section 1179B(1) of that Act relates to a television programme;

(iii) Part 15B of CTA 2009, if the election under section 1179B(1) of that Act relates to a video game;

(b) references to the application of the relevant existing regime are to its application in relation to that film, television programme or video game;

(c) the “relevant closure date” is—

(i) 31 March 2025, in the case of a film or television programme whose principal photography has not begun, or a video game whose production has not begun, by the end of that date;

(ii) 31 March 2027, in any other case.

(7) Nothing in this paragraph expands the circumstances in which the relevant existing regime can apply (except by making it apply in respect of a portion of an accounting period).