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HMRC internal manual

Capital Gains Manual

Persons chargeable: companies

The `profits’ of a company which are chargeable to Corporation Tax comprise income andchargeable gains, and `chargeable gains’ are defined as having the same meaning as for thepurposes of Capital Gains Tax, that is, they are in general computed in the same way, see CG40200+. Although for assessment purposesthe income and chargeable gains are merged into one amount of `profits’, they arenevertheless computed separately so that `income’ losses are not allowable against capitalgains, nor capital losses against income. (See, however, CTM04500 onwards as regards theset-off of trading losses.) There are various rules which apply to particular types ofcompanies and these are to be found in Part VI of TCGA92, see CG41000+.