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HMRC internal manual

Company Taxation Manual

Corporation Tax: trading losses - relief against total profits: restriction of relief for uncommercial trading - meaning of ‘profit’


In the context of S44 (CTM04600) ‘profit’ means commercial profit. For CT purposes, ‘profit’ means ‘income and chargeable gains’. But what S44 is concerned with is the commercial or accounting profit, disclosed by accounts which present a ‘true and fair view’. This means the profits after depreciation and so on, but not taking account of capital allowances or any other tax allowance.