Angelic measure withdrawn

Extra-statutory concession A94: ‘Theatre angels’ will be withdrawn from 31 March 2017.

From then investors’ profits will subject to corporation tax. They will also no longer be able to offset losses against their profits for tax purposes.

For individual investors HMRC proposes to withdraw the concessionary treatment for all new productions from 1 April 2017. Grandfathering arrangements will apply until 31 March 2019 for productions using the concession.

Companies and productions should notify HMRC of their intention to take advantage of the grandfathering arrangements by 31 December. This should be done by emailing here stating the name of the company and the production.

Under the concession theatre angels receive special treatment on the taxation of profits and losses arising from the backing of theatrical productions. As a result profits due to angels could be treated as a deductible expense of the production rather than as a distribution of profit....