FPC30010 - Film Production Companies: Losses: Introduction

FA06/s43 – 45, ICTA88/s393, s393A and s403

The profits or losses of a film production activity carried on by a film production company (FPC) and calculated by following the rules in FA06/SCH4 are profits or losses of a separate trade. Film Tax Relief (FTR) – FA06/SCH5 - can create or augment a loss of a film production activity.

Losses of a trade are normally available:


  • to carry forward against profits of the same trade, set sideways against other profits of the same company or carry back against profits of the same company; and
  • for surrender as group relief.

This normal entitlement to relief for losses of a trade is modified for losses of a trade of film production carried on by an FPC. The modifications:


  • restrict the use of losses for periods preceding that in which the film is completed
  • deem losses brought forward to the period in which the film is completed or later period (to the extent that they are not attributable to FTR) to be losses of the period to which they are brought forward, and
  • provide for a more generous relief for terminal losses.

Guidance on the loss relief rules applying to FPCs’ film production activities

FPC30020Film losses: Pre-completion periods
FPC30030Film losses: Completion and later periods
FPC30040Film losses: Terminal Losses

Worked examples illustrating the practical effect of the rules

FPC30050Film Losses: Example: Film ineligible for FTR
FPC30060Film Losses: Example: Film eligible for FTR
FPC30070Film Losses: Example: Terminal losses applied to new film
FPC30080Film Losses: Example: Terminal losses surrendered