OTR60070 - Orchestra Tax Relief: eligible expenditure: European and UK expenditure - transition rules

For accounting periods ending on or after 1 April 2024, the amount of additional听deduction is no longer based on the amount of qualifying expenditure that is also European expenditure. Instead, it is based on the amount of qualifying听expenditure that is also UK expenditure.听

UK expenditure is defined as: 鈥榚xpenditure on goods and services which are used or consumed in the United Kingdom鈥�.


If a company鈥檚 accounting period听straddles 1 April 2024听and it has incurred qualifying expenditure on a production both before and after that date,听the company may calculate the听additional听deduction for that accounting period as follows:听

The references to 鈥榪ualifying expenditure incurred to date as is UK expenditure鈥�听in (2)(a) and (3)(a)听of s1217RE听of the Corporation Tax Act (CTA) 2009听are to be read as听

  • qualifying expenditure incurred before 1 April 2024听which is European expenditure, plus听

  • qualifying expenditure incurred from 1 April 2024 which is UK expenditure.


If a production enters the production phase before 1 April 2024, the production company can elect听to use European expenditure incurred up until 1 April 2025, and UK expenditure incurred from 1 April 2025.听

For the purposes of this rule, a production enters the production phase when core expenditure (OTR60010) is first听incurred on it.听Note that the test is the date expenditure is incurred; it does not matter if that expenditure is not claimed for relief until a later date, or听is never claimed.听