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HMRC internal manual

Company Taxation Manual

ACT: set-off against CT on profits: definitions

ICTA88/S239 (6), ICTA88/238 (4)

The following definitions applied.

‘The income of a company charged to CT for any period’ was the amount of its profits for that period on which CT fell finally to be borne exclusive of the amount attributable to chargeable gains.

‘The amount attributable to chargeable gains’ was the amount brought into the company’s profits for that period for the purposes of CT in respect of chargeable gains before any deduction for charges on income, management expenses or other amounts which could be deducted from or set-off against or treated as reducing profits of more than one description.

‘The profits on which CT falls finally to be borne’ were the profits charged to CT after making all deductions and giving all relief’s which for CT purposes were given from or against those profits (including deductions or relief’s which under any provisions were treated as reducing them).

The effect of the above was that ‘income charged to CT for any period’ was arrived at after deducting from that income all relief’s given for losses under ICTA88/S393A (1), group relief, charges, management expenses and certain capital allowances under CAA90/S145 (3).